IR 05000289/1977009
| ML19256D355 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/07/1977 |
| From: | Martin T, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19256D353 | List: |
| References | |
| 50-289-77-09, 50-289-77-9, NUDOCS 7910170865 | |
| Download: ML19256D355 (11) | |
Text
.
IE:I Fort:1 12
..
(Jat 75) (Rev)
'
..
,
U. S. NUCLEAR REGULATORY CCMMISSION OFFICE OF INSPECTION GD ENFORCDIENT
REGION I
IE Inspection Report No:
50-289/77-09 Dceket No:
50-289
Licensee:
Metrocolitan Edison Comoany Lxcense No:
DPD-50 P. O. Box 542 Priority:
--
Reading, Pennsylvania 19603
. Category:
C Safeguards Middletown, Pennsylvania Group:
--
Location:
Three Mile Island, Unit 1 Type of Lic,ensee:
Typ-af Inspection:
Routine, Unannounced Dates of Inspection:
March 21-24, 1977 Dates of Previous Inspection:
March 14-18,1977 Reporting Inspector:
d[,u 4.s
T [ Martin @ ctor Inspector DATE Accompanying Inspectors:
None DATE
~
DATE
'
DATE Other Accompanying Personnel:
None DATE 0 C &
'D"' h NI7l'T7 Reviewed By:
,
DATE E. C. McCabe, Jr., Chief, Nuclear Support Section No.
1, RO&NS Branch 1454
'352 I910170 bb
._.
f%
(_)
.
i SUMMARY OF FINDINGS
.
l Enforce..ent Action None.
Licensee Action on Previously Identified Enforcement Items Not inspected.
Design Changes None identified.
Other Significant Findings A.
Cp rent Findings 1.
Acceptable Areas (These are areas which were inspected on a sampling basis s
I and did not involve an Item of Noncompliance or an Unresolved
!
t~'
Item, except as indicated below.)
'
Preparation for Refueling.
(Detail 3)
--
2.
Unresolved Items
.
i (These are items for which additional information is required
!
in order to determine if the item is Acceptable or an Item
of Noncompliance.)
77-09-01: Refueling Procedure Step Completion Certifice-
--
tion.
(Detail 5.b.(2))
--
77-09-02: Snubber Visual Inspection Adequacy.
(Detail 4.b.(1))
77-09-03: Snubber Functional Testing Requirements.
--
(Detail 4.b.(2))
77-09-04: Snubber Operability Requirements.
(Detail
--
-
4.b.(3))
1454 353
._
_ -
.-U
-
77-09-05: Pipe Res'traint Design Basis.
(Detail 4.b.(4).(a))
--
77-09-06: Pipe and Component Restraints and Support Sur-
--
veillance Requirements.
(Detail 4.b.(c).(b))
77-09-07: Snubber with Empty Reservoir.
(Detail 4.c.(1))
--
77-09-08: Snubber with Corroded Piston.
(Detail 4.c.(2))
--
,
77-09-09: Snubber with Mis-Oriented Bull's Eye.
(Detail
--
4.c.(3))
77-09-10: Snubber with Painted Grease Fitting.
(Detail
--
4.c.(4))
77-09-11: Spring Hangers Outside Nc mal Range.
(Detail
--
.
4.c.(5))
77-09-12: CILRT Procedure Adequacy.
(Detail 5)
--
!
B.
Status of Previously Identified Unresolved Items
.
O not inspectea
.
Management Interv. w
A management interview was held at the conclusion of the inspection at the site on March 24, 1977.
Persons Attending Mr. R. Barley, Lead Mechanical Engineer, Unit 1 Mr. J. Colitz, Superintendent, Unit 1 Mr. J. Hilbish, Station Nuclear Engineer Mr. J. O'Hanlon, Unit Superintendent of Technical Support Items Discussed A.
Inspection Purpose.
(Detail 2)
B.
Refueling Preparations.
(Detail 3)
C.
Pipe Support and Restraint Su"veilkree.
(Detail 4)
D.
CILRT Procedure.
(Detail 5)
1454 354
.
.
.
-
.
-.
..-
.
- -.
- -
--
'
.
DETAILS
'
1.
Persons Contacted Mr. R. Barley, Lead Mechanical Engineer, Unit 1 Mr. N. Brown, Administrator, Nuclear and Technical Training Mr. J. Colitz, Unit 1 Superintendent Mr. J. Heverling, Security Specialist Mr. J. Hilbish, Station Nuclear Engineer Mr. R. O'Hanlon, Unit Superintendent of Techr.ical Support Mr. M. Shatto, Engineering Assistant Mr. R. Summers, Engineer to Nuclear Mr. R. VanStry, Administrator, Nuclear and Technical Training 2.-
Purpose i
The inspector informed the licensee that the following items would be covered during the inspection.
Adequacy of Fuel Handling'and Refueling Procedural Coverage.
a.
O b.
Adequacy of Pipe Support and Snubber Surveillance ?rograms.
c.
Adequacy of Containment Integrated Leak Rate Test Procedure.
3.
Preparation for Refueling a.
Scope The inspector reviewed licensee procedures and records to verify that new fuel had been properly received and inspected; and that adequate, approved procedures were available for fuel transfer, recycled fuel inspection, and core verification.
Procedures relative to fuel sipping and core and fuel bundle reconstitution were not examined, since no activity in these areas was planned.
b.
Findings (1)
Procedural Coverage The inspector identified no inadequacies in the licensee's procedural coverage for fuel handling planned during the current refueling outage.
1454 355
_
__.
_ _ _
_
. _ _. _ _ _ _ _ _
._
_
._
.
.
( )
(2)
Step Completion Certification The inspector expressed concern that two procedures to be utilized during the outage, containing significant numbers of prerequisites and required sequential pro-cedural steps, lacked sign off blanks to indicate the completion of these items.
The licensee stated that the lack of sign off blanks was an oversight, and that the procedures were being used as if the blanks had been provid ed.
Further, the licensee completed and approved permanent " Procedure Change Request" forms for the pro-cedures, to ensure that next year's revision would contain signature blanks.
The inspector carries as an unresolved item (77-09-01)
verification that significant prerequisites and steps
,
are being signed off on refueling procedures RP 1502-1
,
and RP 1504-14.
i 4.
Pipe Support and Restraint Surveillance
-
a.
Scope
'
~
The inspector reviewed licensee procedures and records related to pipe support and restraint surveillance to determine the program adequacy.
The inspector examined various pipe supports and restraints to determine their operability.
'
b.
Findings I
(1) TS Table 4.1-2 Technical Specification (TS) Table 4.1-2, item number 11, requires the inspection of Hydraulic Shock Suppressors (Snubbers) on Safety Related Systems each refueling inter-val. This inspection is performed per Surveillance Pro-cedure SP 1301-9.9, Hydraulic Shock and Sway Suppressors, Revision 6, dated July 15, 1976.
In reviewing this pro-cedure for technical adequacy, the following problems were identified.
1454 356
.- -.
.-
.. _ -
.
.
-.
_
- _ _.
-- __.
_. _ _ _ - _ _
.
. _. _ _
__
_
.
(['l
(a) Snubber fluid level acceptance criteria utilized in the procedure does not assure that air will be excluded from the control valve block.
(b) The procedure does not verify that the reservoir bleed hole is clear.
i (c) The procedure does not confirm that sufficient stroke remains to allow for thermal growth without
-
hitting the snubbers' mechanical stops.
(d) The procedure does not verify the adequacy of the snubber orientation relative to sight glass function
.
and bleed hole location.
-
(e) The procedure does not verify the adequacy of the snubber base bushing greasing.
(f)
The procedure does not require inspection for paint or corrosion on the snubber piston.
,
This item (77-09-02) is unresolved.
)
(2)
Functional Testing Current regulatory requirements for functional testing of snubbers are expected to be imposed on the licensee prior to the end of the present refueling outage.
The inspector stated that the licensee's new procedure for snubber functional testing would be reviewed against the following criteria.
(a)
Lock up rate acceptance criteria should demonstrate design requirements are being met.
(b)
Bleed rate acceptance criteria should demonstrate design requirements are being met.
(The inspector expressed specific concern for the criteria applicable to snubbers on relief valve lines.)
(c)
Freedom of motion over the length of the stroke in both directions should be demonstrated.
1454 357
--
.-
.-
. - -..
_...
.
..
-
.-
.
m.
,
(d) Action to be taken upon identification of a frozen snubber should be detailed.
(The inspector identified new piping fatigue cycle life reduction considerations to be incorporated here.)
(e)
Inspection interval specification, requirements for sample rotation and representation, and repeat test requirements for previously failed snubbers should be addressed.
i (f) Hydraulic fluid testing for viscosity and contamin-ation should be addressed.
This item (77-09-03) is unresolved.
,
(3)
Snubber Maintenance
'
Maintenance procedure MP 1410-Y-34, Repair of Hydraulic
'
Snubbers, Revision 0, dated November 7,1976, allows removal of a snubber from service during operation.
The inspector expressed concern that this option was provided without qualification.
Removal of a snubber
.-Ij which is not already known to be fciled, appears to be a voluntary move into a degraded condition.
Revision of the procedure to bound this option is an unresolved item.
(77-09-04)
(4)
Others (a)
The inspector questioned on what basis (Dynamic or Static) the piping restraint system was designed.
This item is unresolved.
(77-09-05)
(b)
The inspector was unable to identify a licensee program for surveillance of pipe or component sup-port or restraint systems, other than that contained in SP 1301-9.9.
This item will be reviewed by NRC management and is unresolved.
(77-09-06)
1454 358
-.
.-
..--.
.
- .
.
-
_
.
O
'
c.
Observations The inspector selected a sample of 7 Grinnell, 4 Basic Engin-eers, and 2 McDowell - Wellman Snubbers for inspection.
In transit to the locations of these snubbers, various pipe and component s'Jpports were also examined.
As a result of the inspector's observations, the following items are unresolved.
j (1) One snubber in the pressurizer cubicle was found to have an empty reservoir.
(77-09-07)
,
(2) Another snubber in the same area had a severely corroded j
piston rod.
(77-09-08)
(3) A third snubber in the area had its reservoir sight glass (bull's-eye) located on top and bottom horizontal surfaces of the reservoir, thereby defeating its intended
,
function.
(77-09-09)
t
(4) Several snubbers had painted grease fittings.
(77-09-10)
i
,m (5) A numt.er of spring hangers had piston settings outside s a'
their normal hot-cold reading range.
(77-09-11)
5.
Containment Integrated Leak Rate Test a.
Scope The inspector reviewed the licensee's procedure for conducting a Containment Integrated Leak Rate Test (CILRT.)
The Sur-veillance Procedure SP 1303-6.1, Reactor Building Integrated Leak Rate Test, Revision 3 draft, was reviewed against the requirements of Appendix J to 10 CFR 50, ( App. J) American National Standard N45.4-1972, (N45.4) and Technical Speciff-cation (TS) 4.4.
In addition, the inspector reviewed the results of the preoperational CILRT to verify the accurac,-
of the proposed reduced pressure CILRT acceptance criteria.
b.
Findings As a result of this review, the following problems with the procedure were identified and are carried as an unrescl red item.
(77.9-12)
1454 359
._
.
_
.
- _ _...
.
_
-..
. - -.
.--
-.
. -. -.
-
.- _.
..-.
i
.
e
(.)
(1)
Section III. A.1.(d) of App. J requires venting and drain-ing of fluid systems which connect to the post Design i
Basis Accident (DBA) atmosphere, to ensure the system's Containment Isolation Valves (CIVs) see the post accident differential pressure and medium. SP 1303-6.1 does not require containment penetrating systems to be treated
'
in this manner; nor does it provide a mechanism for con-servative correction of CILRT results due to failure to perform the required venting and draining.
(2)Section III.A.1.(a) of App. J specifies the method to be utilized in correcting leakage identified during the CILRT and further specifies all subsequent retest require-ments.
SP 1303-6.1 does not meet the requirements of
,
-
the cited section of App. J.
(3)Section III. A.1.(c) requires that containment test condi-tions stabilize for a period of about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> prior to l
the CILRT. The inspector informed the licensee that a minimum acceptable stabilization period must meet the following criteria.
!
O ca) sinimum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> at e test pressure greeter than
or equal to the TS specified value.
,
!
(b) The rate of change of average temperature shall not
exceed 1 F/ hour for the last 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the stabili-
,
l zation period.
i (4)
Section III.A.3.(b) of App. J requires the performance of a supplemental test to demonstrate the accuracy of the test method.
The licensee plans to superimpose a known leakage rate on the containment and compare the change in the CILRT instruments to the known added leakage rate.
The inspector informed the licensee that a minimum accep-table supplemental test must meet the following criteria.
(a) The superimposed leakage rate shall be greater than 25% of the CILRT measured leakage, but shall not be more than 100% of that value.
(b)
The suppler ental test shall not be less than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> in length.
1454 360
_.
-
-
.. -
..-
-
.
.
.
.L
...
..
--.
_.
...
.
lv3
'
(c)
Prior to the supplemental test, containment condi-tions must meet the stabilization criteria of (3)
abov e.
(5) A basic assumption in the CILRT calculational technique is that containment volume remains constant.
The licen-see's procedure does not monitor pressurizer, drain tank, and sump levels to ensure this assumption is valid or that data for conservatively correcting CILRT results is ave lla bl e.
(6) Section 7.8 of N45.4 requires records of outside condi-tions during the CILRT.
The inspector stated that these records should include cloud cover, temperature and barometric pressure; and need not be recorded more fre-quently than hourly.
(7) Section 7.8 of N45.4 requires that a signed and dated pertinent observations log be maintained during the test.
(8)
Criterion X of Appendix B to 10 CFR 50 requires the establishment of a program of inspection of activities
,
affecting quality. The inspector indicated concern that
'
SP 1303-6.1 did not provide specific Quality Assurance Hold Points to ensure these responsibilities are met,
-
f (9) SP 1303-6.1 lacks specific prohibitions against leakage path repairs such as tightening of packing, pipe caps, or valves.
(10) SP 1303-6.1 isolates the Reactor Building Spray Pump packing from test conditions by shutting a manual valve on the pump discharge.
This isolation inserts an arti-ficial leakage barrier that could not be expected to exist under post DBA conditions.
(11) SP 1303-6.1 does not require venting of all pressurized sources which can leak into containment.
Failure to vent these sources can lead to nonconservative in-leakage.
(12) SP 1303-6.1 does not specify the analytical technique to be utilized by the licensee in reducing his data prior to comparison to the CILRT acceptance criteria.
.
1454 361
. _ _.
_._ -.
_
_
.
.
,
'
t I
b*
1
.
This leaves open the option of selecting that technique which places the tested containment in the best light, regardlass of the bias which the technique introduces.
(13)
SP 1303-6.1 does not require that the reported instrument error analysis reflect the number of test instruments actually used during the CILRT.
(14) SP 1303-6.1 does not require that the reported local leak rate test summary data include both as found and as left leakage rate data.
(15) SP 1303-6.1 specifies a reduced pressure CILRT acceptance criteria equal to 0.058 weight percent / day (0.75Lt.)
Preliminary analysis by the inspector would indicate this number is over estimated by a factor of approximately 2.0.
(16)
Section V.B.3 of App. J specifies the requirement fo.-
i analy:is and interpretation of the CILRT results.
The inspector informed the licensee that an acceptable CILRT l
must meet the following criteria.
(
'
\\s (a) Measured leakage rates must be corrected for volume
'
c
-
changes and isolated leakage paths.
(b) The corrected measured leakage rate including instru-ment error must be less than or equal to 75% of the maximum allowable leakage at that pressure.
(c) The corrected measured leakage rate at the upper 95%
confidence level must be less than or equal to 100%
of the maximum allowable leakage at that pressure.
1454 362
.
s
.,,
.,,
. - - - - - - -
-
---
.
--
-
w.
._