IR 05000289/1975004

IE Insp Rept 50-289/75-04 on 750224-27.Noncompliance Noted: Diesel Generator Air Start Sys Mod Completed W/O Prior Generation Engineering Dept Review & Approval

ML20125B085
Person / Time
Site:	Three Mile Island
Issue date:	08/14/1975
From:	Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20125B080	List: IR 05000289/1975004 ML20125B078 ML20125B082
References
50-289-75-04, 50-289-75-4, NUDOCS 7910190584
Download: ML20125B085 (15)

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U '. IUCLEAR REGULATORY CO:0!ISSIC::

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OFFICE OF INSPi'CTIO:: R D C:: FORCE'!E T A

,] . , REGION I IE In'spection Ecport No: 50-289/75-04 Dochet No: 50-289 ,

Licensce: Metropolitan Edison Company License No: DPR-50

P. O. Box 542 Priority:

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Reading, Pennsylvania 19603 Category: C  ;

Middletown, Pennsylvania (Three Mile Island 1)

Location: Safeguards -

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Group: S Type of Licensee: ' ' "' ( )

. Routine Announced 21

Type of Inspection: aa

. 0 Dates of Inspection: February 24-27, 1975 (

1 Dates of Previous Inspection: January 14, 1975 ,

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s porting Inspector: - C / +

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R. L. Spessard, Reactor Inspector Date

Acco=panying Inspectors: NdNE . ;7j

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Date llj id Date i:1

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Date =;x

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NONE h5 other Accompanying Personnel:

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A. B. Davi.3, Senior Reactor Inspector Date Reactor Operations Branch s

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SUFDLWY OF FINDI"CS I... .

Enforcement Action .

nn Items of Noncomplianco-

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Contrary to Criterion III, Appendix B,10 CFR 50 and the FSAR E#"~

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Section 1A, Operating Qu' a lity Assurance Plan,Section III, -

plant design change C/M 0800, Modification of Diesel Generator Air Start System, was completed during 1974 without receiving  :: ,

prior Generation Engineering Department review and approval as required by Generation Engineering l'rocedure GP 1003, Centrol "3;;;, .

of Design Change (Detail 6.1.(3))

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Licensee' Action on Previously Identified Enforcement Items . :EEEE'

En The licensee had taken the corrective actions specified in his letter

' dated January 30, 1975, to the violations identified in Report 50-289/

_ 74-35, Detail '2.a(3)(d) and 2.a(7)(d). This item is resolved. (Detail ,

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6.a. and b.) -

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j' Unusual Occurrences *

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O' An unplanned gaseous release from the Auxiliary Building via the Plant Vent occurred during this inspection. (Nonroutine Report 75-01, Tele-gram to IE:I dated February 26, 1975). (Detail 5) '

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Other'Significant Findings Current Findings

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A,cceptable 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) Plant Operations (Detail 2) Adhe' rence to Commission Order of December 27, 197 .. ..

(Detail 3) * "

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, Corrective action taken to return the Au::111ary and Fuel p Handling Building Ventilation System to within FSAR per- ii"+ -

b> formance specification (Detail 4) 51 p; . Unresolved Items (These arc items for which core information

. is required in order to dctormine whether items are acceptable or Items of Noncompliance) 3.g;;.,. Surveillance / Preventive Ibintenance Program for the

. Auxiliary and Fuel Handling Building Ventilation Syste kl (Detail 4) E.: .W T

' Licensee actions relative to the unplanned gaseous release on February 24, 197 (Detail 5) Licensee submittal of a report to the Commission pursuant to R. G. 1.2 (Management Interview, Item 6) .. ;

= . . Status of Previous Unresolved Items h 1 The following items were reviewed and are acceptable: j

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. . , Administrative Procedure for Auxiliary Log Sheets.*  ;

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g- Control Rod Drive Repatching Procedur (Detail 6.e)

V' General Employee, Industrial Health and Safety Train- FE in (Detail 6.f) .

' Operating Procedure OP 1102-4 (Detail 6.a) Evaluation of Existing Temporary Shieldin (Detail 6. h) Snubber Seal Replacement Program (Detail 6.1) Piping Vibration in "A" Makeup Pump Section Line (Detail 6.j)

GORB Review of Technical Specification. Changes 4 and (Detail 6.k) l'ana gencn t Control of 8 Design Changes (Detail 6.1)

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aU l The following itw.s were reviewed and remain unresolved:

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u FSN1 Amendment - Post Accident Purgo Syste (Detail 6.c) iiin

• A0 74-13 Corrective Actio (Detail 6.d)

3. .. Licensec Acceptance of MCP-15 Test Dat (Detail 6.g)

}!anagement Interview '

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.r Anthis of exit!inspectio interview was held -onsite on February 27, 1975 at the conclusion ?

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Personnel Attending: 1 Mr. J. Herbeiri, Station Superinrendent Mr. J. Colitz, Unit 1 Superintendent  !! Mr. J. Floyd, Supervisor of Operations 7 Mr. J. O'Hanlon, Nuclear Engineer Mr. W. Potts, QC Supervisor The following summarizes the items discussed: '

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q _j} Review of Plant Operations including resolution * of an unresolved

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item (Detailand2)methods for enhancing the eff ectiveness of station log .

Adherence to Commission Orde (Detail 3)

. * 'i l Performance of the Auxiliary and Fuel Handling Building Ventilation

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System including the unresolved ite i (Detail 4) .

' E.{i g The unplanned gaseous release including the unresolved ite ..\

(Detail 5) ' ..

,.. Licensee action on previously identified enforcement v.td unresolved items including cation the current status of these items e d the identifi-of the apparent Item of Noncomplianc (Detail 6) The licensee was informed that the FSAR (Section 13) required vibra-tion measurements on reactor internals be performed in accordance .ith

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with RG 1.20, but that the licensec had not submitted a report to

.the .Cor:r.lsnion as required by Paragraph D. 4 of RG 1. 2 The licen-(~g sec stated that a report would be submitted. The inspector also :a

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U informed the licensee of the typographical error in Paragraph of RG 1.20, i.e., C.5 should read C.6. Item is unrer.olved pending ..=

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submittal of this report to the Commissio ' " ~

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52 The inspector was informed ~by the licensee that due to procurement c,.:;;;

problems the modification to the Reactor Building Personnel Hatch 25 door interleck system could not be completed by mid-April 1975, as E=

• previously committed to IE:I (Report 50-289/75-01, Detail 3.b) . ja;EL The licensee stated that this change would be completed by June, ~

'1975. The inspector acknowledged this informatio ,

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DETA1LS

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..n.... Perrens Contacted Mr. J. Barton, Startup and Test Panager, GPUSC

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Mr. K. Beale, Radiation Protection Supervisor Mr. E. Bulmer, Lead Mechanical Engineer Mr. J. Colitz, L* nit 1 Superintendent Mr. W. Cotter, Mechanical Engineer

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Mr. J. Floyd, Supervisor of Operations Mr. C. Hartman, Electrical Engineer Mr. J. Herbein, Station Superintendent Mr. G. Kunder, Mechanical Engineer Mr. L. Lawyer, Manager, Operational Quality Assurance Mr. B. McCutcheon, QA Engineer Mr. G. Miller, Unit 2 Superintendent Mr. J. O'Hanlon, Nuclear Engineer

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Mr. V. Orlandi, Lead I&C Engineer Mr. R. Porter, Shift Supervisor Mr. W. Potts, QC Supervisor Mr. M. Ross, Shift Supervisor

.y,,; Mr. J. Seelinger, Supervisor of Training ,

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Mr. M. Shatto, Mechanical Engineer ( ) Mr. D. Shovlin, Supervisor of Maintenance .

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Mr. B. Smith, Shif t Supervisor -

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Mr. R. Suc=ers, Project Engineer (Mechanical) Review of Plant Operations

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The following items, which were not reviewed during inspection number 50-289/75-01, were examined during this inspection: Computer Printouts O!idnight)

Records for the period December 21-31, 1974, were reviewe Values for Reactor Power, Imbalance, Quadrant Tilt, Reactor Coolant Pressure and Flow, and Rod Withdrawal Index were observed to be in accordance with Technical Specification requirement u ..

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Records for the period February 30-20, 1975, were reviewe .Te

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-Entries were observed to be in accordance -ith AP 1016. Re- *

vision 5, Section 4 (Proposed)'. . . . _

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. Primarv Auxiliary Onerators Log - Tour Readings Records for the period February 10-20, 1975, were reviewe Entries were observed to be in accordance with AP 1016. Re-

, vision 5, Section 4 (Proposed).

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R i 2: 1 ' Primary Auxiliary Operators Log - IRDS Pancis

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m Records for th'c period February 10-20, 1975, were reviewe Entries were observed to be in accordance with AP 1016, Re- :;g vision 5, Section 4 (Proposed). Secondarv Auxiliarv Operator Log Sheets *

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Records for the period February 10-20, 1975, .were. reviewe Entries were observed to be in accordance with AP 1016, Re- _5 g; f vision 5. Section 4 (Proposed). -

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. Out-Building Tour Log Sheets (Auxiliary Operator) -

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Records for the period February 10-20, 1975, were reviewe O zactie were ob ervea ce be 1= eccere==ce wicb ^r tote. ne-vision 5, Section 4 (Proposed). - Administrative Procedure for Auxiliary Log Sheets

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The inspector observed that Section 4.0 (The Operations Sur- [

veillance Program) of AP 1016 had been recently revised (Proposed Rev. 5). This procedure change had been. reviewed by the PORC and approved by the Station Superintendent. How-ever, since this procedure is also an implementing procedure of the Operational Quality Assurance Plan, issuance of this revision had been delayed pending concurrence of the Manager, :

Operational Quality Assurance. Section 4 of AP 1016 (Pro- ~

posed Rev. 5) governs the use and evaluation of the data EE sheets identified in 2.b. thru f. above in addition to.other

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aspects of the surveillance progrcm. The inspector's pre ~teus concern re;;arding this matter is considered resolved (Repn: .a /7'-35.- oeceit 2 "- (2) ==a nevert 50-2s9/ 75-o1. oec=11 8. g) .

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Additionally, the inspector and the licensee discussed methods of enhancing current data sheet contents and documentation practices relative to impicmentation of that portion of the sursc111once program encompassing the data sheets identified ...

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in 2.b.'thru f. abov .

The inspector has no further questions

of this matter at this tim ,

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; Problem Identification Systems .;;; I'he follouing systems utili

ed by the licensee to identify *

problems were examined to determine if identified problems 3 involved Technical Specification reporting or LCO require- n'

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(1) PORC Meetings PORC Meeting Minutes (No. 259-266) for the period Dec'em-ber 2,1974 - January 24, 1975 were reviewed with respect O to their evaluation of problem Findings were acceptabl 'k )

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One of these items involved a reevaluation of the r'sults e

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for TP 151/1 Reactor Building Isolation Valve Leak Tes The licensee discovered that during the performance of this preoperational test, calibration data for certain flow . E=

instruments for measuring valve leakage was used incorrectl As a result, the original data was reevaluated and accepted by the license The test results showed that although the valve leakage was more than originally calculated, the test results (as corrected) still meet Appendix J to 10 CFR 50 requirements, i.e., total Type B and Type C leakage was 0.366 La .Y.s the acceptance criterion of <0.6 La (Appen-dix J limit). The licensee intends to report this matter in his Semi-Annual Operating Report pursuant to Technical Specification 6. Additionally, the licensee has taken steps to insure this type of error is not made during future surveillance tests conducted pursuant to Technical Specification 4.4. The inspector has no further questions on this matter at this tim ,

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". m A second item involved the licensec's cen:inuing evalun-tion concerning crosion of the :theup prp bypass orifices n-;;

t (Reference: Report 50-289/74-33, Lutails II, 4.).

' k] orifices (design #2) for the A and B 1hkeup Pumps show The

%sEE (by radiography examinations) erosion cf the 2nd, 3rd, =.: -

and 4th plates, but no pipe wall dam.:ge. The erosien .

appears to have stabilize The C Maheup Pump is normally in standby, and its orifice (design i2) shows no apparent erosion. The original letdown bloch orifice, which had

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exhibited crosion damage, was replaced eith a design #3

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orific Radiography examination of this new orifice ..n'

shows no apparent crosion to date. The licensee has E_

xevised his surveillance program from vechly to monthly [

radiography examinations. Three replacement orifices 1 (design #3) for the Makeup Pumps are onsite, and two of d these have been approved for installatien. The remaining *

orifice remains in QC hold pending acceptcnce by the M licensee. Plans are to replace the bypass orifice on each Makeup Pump at a time convenient to the licanse ;;;;;

The inspector has no further questions on this catter at this tim lisii i (2) Maintenance Work Requests .

WR's 6869, 6733 and 6647 containing PORC review and the v Station Superintendent's approval ware reviewed. Find- -

ings were acceptabl N (3) Staff Meetings

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The inspector attended the daily staff meeting on Febru-ary 27, 1975 where the Plan of the Day was reviewe Findings were acceptabl E Facility Training Program Two licensed operators were questioned on the contents of Abnormal Procedure 1203-1 Load Rejection (one of the procedures covered during a recent training session) to verify a knowledge commensurate with the licensee's documentatic The inspector determined that the operators were familiar with the contents of this procedur No attempt uss made to evaluate the com- =

petency of these operators to stand a watc n

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t' On February 27, 1975, the inspector was inform:d that the last L" tour made by the Station Superintendent occ cred on the pre-vious da . Order for l'odifico lon of License ],',,

The inspector observed that Operating Procedure OF 1102 '., Revision 5 (Power Operations) was consistent with the requirements of the o ,

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Co:r..iission Order dated December 27, 197 On February 26, 1975, control rods ucre observed to be positioned in eccordance uith OP 1102-4, Revision Additionally, the licensee's analysis of the Maximum Linear Heat . Rare (MLHR) (daily computer printouts Group 20 1 and 34) is being compared with the most restrictive values. Data j

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indicates the MLHR is substantially below the most restrictive b value ;;;;; ;

. ." Performance of the Auxiliarv and Fuel Handline Buildine Ventilati,on, Systen

Rsferences: Report 50-289/74-31, Detail 2h .

. .e . Nonroutine 30-Day Report 74-01, dated November 8,, 1974 .

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Based on a review of records, discussions with c.he licensee, and !r (V*) observations during a tour of the Control Room and the Auxiliary Qv and Fuel Handling Building, the inspector determined the licensee's corrective actions described in the referenced nonroutine report

had been completed and the ventilation system flow rates were in ,

accordance with FSAR design requirements. The inspector.has no further questions on this matter at this tim J The inspector questioned the licensee about what actions would be taken to insure that the performance of this syst.cm does not deteriorate below FSAR design requirements over the lifetime of the plan The licenseo stated that a surveillance / preventative maintenance program would be developed and implemente The de-tails of this program were not established during the inspector's discussions with the licensee; however, the licensee belle red that the monitoring and evaluation of key paramercrs, such as system flows, filter LP's, static pressure regulator settings, local air flow direction measurements, etc. could be cacily factored int: the y current operater surveillance progra Additionally, the licensee has ordered a 6 foot long pitot tube for making more refined air j 90012555

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' _ h flow measurements of this syste The development and implementc-

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tion of a suitable program is considered to be an unresolved iten is pending completion by the licensee and review by IE: ;;; e Unplanned Caseous Release During this inspection, the licensee informed the inspector that 5.T ...

an unplanned relcase had occurred on February 24, 197 The de-- """""

tails. of the release, which were documented in the licensee's tele- ,

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gram to IE:I dated February 26, 1975, were discussed with the ..

licensee. The inspector noted that Technical Specification release y limits were not violated and that plant personnel had not been i:r ..,

exposed to ' excessive concentrations pursuant to 10 CFR 2 This -

matter is considered to be an unresolved item pending the licensee's ,  ?

submittal of the required 10 day report and IE:I evaluation of this n report and inspection followup, if necessar , Enforcement and Unresolved Items from Previous IE Inspections - il Failure to Comolv with Technical Specification 3. 5. 2. 4. and 10 CFR 50.36(c)(2)  ::U References: (1) IE:I letter dated January 3,1975 and -

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Report 50-289/74-35, Detail 2.a(3)(d)

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(2) Report 50-239/75-01, Detafi 8. f ,

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(3) Met Ed letter dated January 30, 1975

.O Based on a review of OP 1102-4, Revision 5, a review of the Revised procedure Review Book, and discussions with licensee management and Shift Supervisors, the inspector det'ercined <M that the licensee's action described in Reference (3) was E completed as stated with the following exceptio The modification to the Reactor Protection System is to be con-pleted by June,1975 per Reference (3), and therefore, was not included in the inspector's review. This item'is resolve Failure to Comply with Technical Specification 6.7.2. References: (1) IE:I letter dated January 3,1975 and Report 50-289/74-35, Detail 2. a. (7)(d)

(2) Met Ed letter dated January 30, 1975 ~

3ased on discussions with licensee management and PORC members, the inspecter determined that the licensee' action describud in Refereace (2) was completed as stated. This itcm is resoP. '.

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d FSAR Arendr.ent - Pnst Acc.ident Purce Systc= '

p d Reference: Report 50-289/74-18, Detail 3. b. si) (s)  :

The inspector was informed by the licensee that Reactor Licen-

sing (RL) had been advised of this matter and that a TSAR g amendment was in preparation for submittal to RL. Item rcmains =E unresolved pr.. ding submittal of the amendmen ;) :l AO 74-13 Corrective Action g

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Ref ere,n ces : (1) Report 50-289/74-30, Detail 2 [3  !

(2) Report 50-289/74-35, Detail The inspcetor was informed by the licensee that' numerous difficultier, had been ancountered in obtaining a suitably '

qualified (Seismic) replacement switch and that Met Ed 5 Engineering had selected a switch which would be evaluated by the licensee's A Following qualification of the replace- -'" . , . . .

ment switch the licensee intends to install it on.a priority

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basis. Item remains unresolved pending completion by the ,

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. Contrcl Rod Drive Repatching Procedure ,- ...

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Reference: Report 50-289/74-29, Detail The inspector observed that SOP 156, CRD Repatch 253 Days Core 1, dated February 21, 1975 had been issued. This procedure is to be used in conjunction with OP 1105-9 for repatching control rods following 253 1 10 EFPD of operation. Item is resolved, General Employce, Industrial Health and Safety Training .

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y Reference: Report 50-289/74-32, Detail d Based on a review of records and discussions with the licensee, the inspector determined that the licensee had established definitive requirements relative to control of personnel attend-ing the subj ect training lecture These requirements are contained in Trair.ing Department Administrative Memo "o. 7, dated :;ovember 22, 1974. Item is resolve '

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-: a O neferencc: Renert 50-289/74-33, Deta11 1, 2. 0

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c; Based en a review of records and discussicas with the licensee, y the inspector determined that testing uns cc plete, the data

package including CPUSC QA signof f was turncJ over to Met Ed in January,1975, and review of the data packase by Met Ed was In propres Licensec review relative to dat.. acceptanc2 was  :

about 50.; complete, and the licensce's target date for completion .

was the end of April.197 Item remains unresolved pending .1:. j completion by the licensee.- -

" " Evaluatien of Existing Temporary Shielding References

(1) Report 50-289/74-35, Detail 2.b.(5) . .q (2) Report 50-289/75-01, Detail *

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T. '. i Based on discussions with the licensee, the inspector learned that the Supervisor of Operations evaluated the existing shielding and determined that no restrictions e::iste Addi-tionally, future shielding installations are to be of a maze ....

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design to allow easier access for valve operatien and packing -

] adj us tments . During a tour of the Auxiliary Building, the j inspector . observed shielding installed in accordance with the '

=..y, Item is resolve new guideline _ Snubber Seal Replacement program References: (1) Report 50-289/74-35, Detail 2.b. (8) . (2) Report 50-289/75-01, Detail '

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Based on a review of records, discussions with the licensce, and observations during a tour of the Intermediate Building, the inspector determined that the licensee has implemented the -

subj ect program. The work is being performed in accordance with an' appropriately approved Work Request (WR 4438) which includes detailed steps for rebuilding, an accep,tance test of the rebuilt units, QC signoff, and reinstallation instruction One maintenance crew has been specifically assigned to perform this task. Appropriate records and QC Surveillance Reports were

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readily availabic and reflected the current status of the program "'~

which was about 15'; complet The program was at a standstill 90012558 ,

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at the time of this inspection due to a shcrtare of hydraulic j g- - fluid, but is to be resurzod when the fluid is receive T ;;;:

s date most of the work has' taken place in cl e Intermediate ="

Building and has involved 'the 1 bin Steam, Feedwater, and Emergency Fcedwater Systems. The licensee anticipates com- !i pleting this prugram by the end of the first refueling (sche-dule.d Ibrch, 1976). This item is resolve Piping Vibration in "A" Malmup Pumo Suetion Line .

Reference: Report 50-289/75-01, Detail 2.b.(7) -

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_ Based on a review of records and discussions with the licensee, the inspector determined that this matter was reviewed by the licensee's AE and the POR It was determined that the vibra-tion levels were acceptabl This item is reslove . CORB Review of Technical Specification Changes 4 and 5 '

t Ref er ence: Report 50-289/75-01, Detail Based on a review of records, the inspector determined that .g;;,,

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the GORB had reviewed the subject change This was documented (' g 1 in a letter from the GORB Chairman to the Met Ed Vice President (Generation) . Additionally, this is to be further documented

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in the minutes for GORB Meeting No. 17. This item is resolve O 1. 1bnagement Control of Design Changes

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Reference: Report 50-289/75-01, Detail 6.b(2)

Based on review of records and discussions with the licenseec the inspector determined the following relative to the licen-see's control cad review of the 9 design changes identified in the referenced report:

(1) Design Change C/M 0135 involved a change to the Integrated Control System, and this system is not included in the Quality Assurance Systems List (GP 1003). Therefore,

design control via the QA Program for Operations and _

likewise Technical Specification 6.1.I.2.b.2) was not require Appropriato control for this change was accomplished via AP'101 Item is resolve .

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(2) Design Changes C/110076, 0031, 0063, 0039, 0071, 0048 and 0102 were nccomplished in accordance with the CPUSC Start-up and Test QA Plan,Section III (Procedure AEFCP-1). This control is consistent with the licensc.'s Operational Qual-ity Assurance Plan described in the FSAR (Section 1A). .

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Item is resolve =

s (3) Desi,r. Change C/M 0080 involved a change of the Diesel 4:ij Ger.erator Air Start System, and this system is included h in thc. Quality Assurance Systems List (GP 1008). The change was accomplished in accordance with AP 101 Records indicated that no attempt war made to control,this 3 change via the GPUSC Startup and Test QA Plan, but rather 7;; 3:J

.the change package had been' forwarded to Met Ed Generation Engineering. The licensee was unable to provide documen- ,

tation relative to Generation Engineering Department's '

review and approval of this change prior to the change .g . ,

being mad Additionally, the licensce stated, during the referenced inspection, that this review and approval had . . .

not been accomplishe ~

m Failure to control this design change is contrary to the .

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requirements of Criterion III, Appendix B,10 CFR 50 and :W

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the FSAR Section 1A, Operating Quality Assurance Plan, '

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) Section II The 00A Plan,Section III states in part, that '" Design control is implemented by means of Generation

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A Engineering Procedures which include: ... design review i(

U requirements. . ." GP 1003, Control of Design Changes re- R

quires specific design control measures to be'taken to . .;

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assure review and approval at the corporate level prior to implementing the chang Failure to control this change at the corporate level is also contrary to Technical Specification 6.1.I. 2.b. 2). This finding of noncomplidnce is considered to be an infractio ,_s G

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