IR 05000289/1978014

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IE Insp Rept 50-289/78-14 on 780612-15.Noncompliance Noted: Failure to Initiate Procedure Change Re Rod Insertion Limits
ML19276H229
Person / Time
Site: Crane Constellation icon.png
Issue date: 07/06/1978
From: Conte R, Haverkamp D, Keimig R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19276H222 List:
References
50-289-78-14, NUDOCS 7910150856
Download: ML19276H229 (13)


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v.S. NUCLEAR REGULATORY COMMISSivd CFFICE OF INSPECTION AND ENFORCEMENT Region I 3;; ort No.

50-289/78-14 Docket No.

50-289 License No.

DPR-50 Priority Category C

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Licensee:

Metrocalitan Edison Cc'.cany

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P. O. Box ~542 h

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l-Readina, Pennsylvania 19603

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Facility Name:

Three Mile Island Nuclear Station, Unit 1 Inspection at:

Middletown r Pennsylvania Inspection conducted:

dune 12-15,1978,

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Inspectors:

A bwD 7f c Ii 9 R. J. Conte, Reactor Inspector cate signec hIf ~

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D. R. Haverkamp, Reyctor Inspector cate signed O CJ, A h

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W. H. Baunack, Reactor Inspector

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care signea Acccmpanied by:

R. P. Zimmerman, Reactor Inscector

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cate signea Approved byj

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N 7/6 /7 '?

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/ TL R.t T. Yeimig. Chief. Nticlear Support care signea r

Section No. 2, R0aNS Branch (,

Insoection Summary:

Inscection on June 12-16, 1978'(Recort No. 50-289/78-14)

Areas Inscectec:

Routine, unannounced inspection of acministrative controls for Tecnnical Specification (TS) surveillance requirements and for s'afety related main-tenance; selected TS surveillance recuirement test procedures including test data; documented activities associated with safety related maintenance; qualificaticn records of selected individuais who performed safety related maintenance; the ::er-ferman< e of selected surveillance tests; and, multi le red drop inciden: en June la, 1975.

The inspection involved 56.5 instector-hours ansite by 2 '!RC ins; ectors.

Resul 3:

Cf :ne six areas ins:ec:ec, no ite's of ncnc mciiance aere icenti#iec in

" ce areas; One at arent i e Of ncnc: :liance was founc in :ne area (Deficiency -

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ini-iate a :r cecure :nange
aracra:n 2.:(2)).

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DETAILS 1.

Persons Contacted M. Beers, Shift Supervisor W. Cotter, Supervisor, Quality Control W. Herman, Test Coordinator

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  • G. Kunder, Supervisor. Technical Support L. Noll, Shift Foreman
  • M. Ross, Operations Supervisor W. Sawyer, Supervisor of Maintenance H. Shipman, Operation! Engineer Other licensee employees including members of the technical, opera-tions and administrative staffs were interviewed.
  • denotes those present at the exit 'nterview.

2.

Administrative Controls for Surveillance Procedures The inspector performed an audit of the licensee's administrative con-

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trols by conducting a sampling review of the below listed administra-tive procedures with respect to the requirements of the Technical Specifications, Section 6, " Administrative Controls," ANSI N18.7,

" Administrative Controls for Nuclear Power Plants" and Regulatory Guide 1.33, " Qual.ity A_x cance Program Requirements.

Administrative Procedure 1001, Document Control, Revision 13;

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s March 30, 1978.

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Administrative Procedure 1007, Control of TMI Records, Revis-

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ion 3, December 13, 1977.

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Administrative Procedure 1010, Technical Specification Surveil-

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lance Program, Revision 12, November 8, 1977.

No items of noncompliance were identified.

3.

Surveillance Testina

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a.

The inspector reviewed surveillance tests on a samoling basis to verify the following.

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Tests required by Technical Specifications are available

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and covered by properly approved procedures.

Test format and technical content are adequate and pro-

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vide satisfactory testing of related systems or components.

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Test results of selected tests are in conformance with

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Technical Specifications and procedure requirements have been reviewed by someone other than the tester or individual directing the test.

b.

The following surveillance tests were reviewed to verify the.

above.

Surveillance Procedure 1303-3.1, Control Rod Movement,

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Revision 2, December 4, 1974. Data reviewed for 11 sur-veillances performed January 14, 1978 to June 3, 1978.

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Surveillance Check 1301-9.2, Control Rod Program, Revision 11, March 14, 1978.

Data reviewed for tests performed May 9,1977 and April 26, 1978.

Surveillance Procedure 1303-11.2, Pressurizer Code Safety

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Valve Setpoint Verification, Revision 4, March 22, 1978.

Data reviewed for tests performed April 17-22,1977 and April 24, 1978.

Surveillance Procedure 1303-1.1, Reactor Coolant System

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Leak Rate, Revision 7, May 25,1976. Data reviewed for 21 surveillances performed May 18, 1978 ta May 31, 1978.

Surveillance Procedure 1303-11.8, High and Low Pressure

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Injection, Revision 5, March 15, 1978.

Data reviewed

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for tests performed March 20, 1977 and March 18, 1978.

Surveillance Procedure 1303-11.20, Reactor Building Access

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Hatch Interlocks, Revision 0, April 4,1973. Data reviewed for test performed April 19, 1978.

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Surveillance Procedure 1303-12.3, Venting of Makeup Pumps and High Pressure Lines, Revision 0, October 20, 1975.

Data reviewed for tests performed March 25, 1978 and April 25, 1978.

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Surveillance Procedure 1303-12.4, Venting of Decay Heat

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Pumps and Low Pressure Injection Lines, Revision 0, October 26, 1976.

Data reviewed for test performed April 14, 1978.

Surveillance Procedure 1303-6.2, Hydrogen Purge Operating

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Test, Revision 2, April 15, 1977.

Data reviewed for test performed April 16, 1978.

c.

As a result of the above review, the following items were identified:

(1) Surveillance Procedure 1303-11.20, Reactor Building Access Hatch Interlocks, written to satisfy requirements of Technical Specification 4.4.1.6, does not verify the operability of the centrol room annunciator circuits for the personnel and for the emergency access hatch door interlock. The switches installed to monitor interlock operability only provide indication that bo-h hatch doors are open; they do not provide interlock status indica-tion.

This matter will be reviewed further by RI and the

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licensee.

This item is unresolved.

(289/78-14-01)

G (2)

Surveillance Procedure 1303-12.3, Venting of Makeup Pumps and High Pressure Injection Lines, written to satisfy requirements of Technical Specification 4.5.2.1, does not provide for venting of the high points in the high pres-sure injection lines.

Vents are provided on the pumps and the pump suction line high point; however, no vents are installed on the high point of the pump discharge lines.

The pump discharge lines are the highest points in the system.

The licensee representative stated that tha cperating fill and vent procedures adequately fill and purge these lines.

This matter will be reviewed further by the licensee.

Pending completion of this review, this item is unresolved.

(289/78-14-02)

(3)

Surveillance Procedure 1303-3.1, Control Rop Movement, Step 6.10 could not be performed as specified by the. pro-cedure due to a change in Technical Specification rod in-sertion limits imoosed following the last refueling which ended April 26, 1978.

The surveillance was performed on

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four occasions folicwing the refueling (Acril 26, May 1, May 20, and June 5, 1973) with no precedure change initi-a ed o reflect -he stees ac ually :erfor ed to sat.isfy tre surveillance recuiremen s.

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Failure to initiate a procedure change to document a devia-tion from an approved procedure is considered to be con-trary to Technical Specification 6.8.1 and is considered to be an item of noncompliance (289/78-14-03) at the deficiency level.

4.

Inscector Witnessina of Surveillance Tests a.

The inspector witnessed the performance of surveillance testing of selected components to verify the following.

Surveillance test procedure was available and in use.

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I Special test equipment, if required by procedure, was cal-

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ibrated and in use.

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Test prerequisites were met.

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b.

The inspector witnessed the performance of:

Surveillance Procedure 1301-6.7, Monitoring of Silt Build-

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up in River Water Screen House, Revision 3, March 7,1978.

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Performed June 12, 1978.

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Surveillance Procedure 1303-4.16, Emergency Power System,

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Revisio'n 12, June 28, 1977.

Performed June la,1978.

No items of noncompliance were identified.

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Administrative Controls for Safety Related Maintenance i

Administrative controls were reviewed to determine the licensee's program for implementing requirements associated with the conduct-

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of safety related maintenance as specified in Technical Specification Section 6; Regulatory Guide 1.33; Quality Assurance Program Require-

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n;ents; and, ANSI 18.7, Administrative Controls for Nuclear Power Plants.

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The following documents were reviewed:

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1021, Plant Modification, Revision 1, January 17, 1978;

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1026, Correc-ive Maintenance and Machinery History, Revision 6, May 1,1978 ; anc,

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1027, Preventative Maintenance, Revision 4, February 3,1978.

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tio items of ncnccmpliance were identified.

6.

Review of Safety Related Maintenance Activities

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a.

The inspector reviewed safety related maintenance conducted by the licensee on a sampling basis to verify that:

Technical Specification Requirements were met while

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ecuipment was out of service, and a Licensee Event Report was submitted for mainteaance associated with a report-able occurrence; Required administrative approvals were obtained to perform

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the work; An approved procedure was used where appropriate;

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Required inspections were perfor ed; and,

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Records to substantitate quality of work and parts used

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were available (this includes documentation associated with procurement, inspections and test rqsults).

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b.

Documentation of the following maintenance activities were reviewed:

22479, Boric Acid Lines (7% Tank to 4% Tank), unblocked,

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perfonned March 31, 1978; 22498, Control Rod Drive Mechanisms - cleaning and tighten-

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ing of selected terminal connections, performed March 23, 1978.

21914, Reactor Protection System - operability check of

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Reactor Trip Module, Channel C and circuit breakers CB 1 and 2, performed tiovember 14, 1977;

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22435, Reactor Building Spray Pump (SS-P-1A) Discharge

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Pressure Gage - recalibrated, perfccmed January 16, 1978;

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21338, Reactor Coolant Pump (RC-P 1A) - replaced leads /

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cacacitors in motor controller, perfor.ed September 19, 1977; 21514, Makeup Letdown Cooler (MU-C-1A) - hydrostatic test

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of removed cooler, performed January 3-5, 1978;

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22838, Engineered Safeguard Actuation System Cabinet B -

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replaced pressure transmitter and buffer amplifier, performed March 6, 1978; 22625, Decay Heat Removal Pumps (DH-P-1 A and 18) - dis-

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assemoled and renewed including shaft replacement, April 25, 1978; i

I 22083, Reactor Building Personnel Access Door - replaced

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cam follower, performed December 4,1977; j

20336, Nuclear Service River Water Strainer (t1R-S-2C) -

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work was in progress for replacement of strainer, initi-ated June 13, 1978;

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i 22792, Turbine Sampling - installation of a temporary

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vacuum gage, performed February 16, 1978; 22621, Nuclear Service River Water Strainer (NR-S-18) -

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cleaned and replaced overloads in motor controller, performed January 27,1978; and, 22793, Diesel Generator Relay (Service A) - relay appeared

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to be sticking - car. celled upon re-evaluation of problem as nonexistent, initiated February 1, 1978.

flo items of noncompliance were identified.

c.

Documentation of the folicwing maintenance activities were re-viewed specifically to verify compliance with respect to established administrative controls fer the ccmpletion of

" Work Recuest Approval" forms and for procedural' coverage associated with the maintenance activity:

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22012, W&ste Disposal Liquid Tank (WDL-T-8) - inspection,

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performed December 11, 1977; 22054, Reactor Building Purge Supply Fan Flow Switch (PB-

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B-69) - replaced, performed February 6,1978;

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22082, Main Feed Pump B Flow Orifice - Primary and Second-

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ary Root Valves replaced, performed April 12, 1978;

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22098, Reclaimed Boric Acid Pump (WCL-F 135: - tightened

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set screw on local centrol switch, perf]rmed February 1, 1978; 22117, Inverter 1C - adjustments to running frequency and

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synchronization circuits, performed December 13, 1977; 22122, Solenoid Valve for Letdown Block Orifice Isolation

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Valve (MU-V-4) - disassembled and cleaned, performed December 7, 1977; 22169, Inverter IC, adjustements to running frequency and

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synchronization circuits, performed December 15, 1977; 22218, Decay Heat Remov'l River Water Pu:qp (DR-P-23) -

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packing adjustment, performed January 14, 1978;

22877, Pressurizer Heater Resistance Readings Preventa-

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tive Maintenance, performed April 5, 1978; 23665, Reactor Building Personnel Access (Outer) Door -

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replaced limit switches, performed May 6,1978; 23649, Fire Service Deluge Valves in Cooling Tower S Area

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- selected valves reset, performed May 1, 1978; and, 22783, Fire Service Deluge Valves in Cooling Tower B

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Area - reset deluge valve and opa.ned associated isolation valve FS-V-188, performed February 15, 1978, No items of nonccmpliance were identified.

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7.

Maintenance Personnel 01alifications The inspector reviewed the qualification records of selected techni-cians and craft personnel who performed maintenance on rafety related systers, and components to verify that the individual's experience

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level and training were in accordance with the guidelines of ANSI N18.1 -1971, Selection and Training of Nuclear Power Plant Personnel, Section 4.

No items of noncompliance were identified.

8.

Facility Tour On several occasions during the inspection, inspection tours of the facility were conducted of both the turbine and reactor buildings.

During the tours, the inspectors discussed plant operations and ob-served housekeeping, raoiation control measures, monitoring instru-mentation and controls f or Technical Specification compliance.

In addition, the inspectors observed control room operations on both day and evening shifts for control room manning, shift turnovers,

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and facility operati;n in accordance with administrative and tech-nical specification recuirements.

A recovery from an unscheduled control rod grcup insertion, described in Paragraph 9 of this re-

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port was also witr essed.

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No items of noncompliance were identified.

9.

Multiole Rod Droo Incident On June 14, 1978 the licensee reported to Region I that a violation of a limiting condition for operaticn had occurred that morning when seven of the nine control rods in safety group 3 inadvertently.

dropped into the core.

This resulted in operation with more than'

one inoperable safety rod, which is a violation of T.S. 3.5.2.2.a and which also violates the safety red limits of T.S. 3.5.2.5.e.

During the transient, the quadrant power tilt limit of T.S. 3.5.2.4.a was exceeded, but the tilt was returned to within allowable limits within the four hour time limit of T.S. 3.5.2.4.e.

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The seven safety rods in group 3 dropped into the core while per-forming an RPS surveillance, which required manually tripping two of the four 'DC power hold supplies for the rod group.

The remain-ing two power supplies are normally sufficient to hold the rods.

However, one of the power supplies had several blown fuses so that there was insufficient voltage to hold the rods. The cause of the blown fuses was being investigated.

The dropped rods resulted in a rapid power reduction from 100*,' to

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about 40 full power.

While plant conditions were being stabil-ired, core power distributions and other core physics data were being analyzed.' Licensee representatives determined from the Technical Specifications that operation with more than one inopera-ble rod was not allowed, but no time clock was provided for shutdown.

Therefore, an orderly power reduction was begun. Meanwhile, all group 3 safety rods were aligned at 20*.' withdrawn within one hour afte" the rods had dropped, and were fully withdrawn within the next twenty minutes.

The shutdown evolution was then stopped with reactor power at 30% full power and power escalation began when conditions stablized.

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The inspector reviewed the licensee's actions regarding this incident for conformance with applicable recuirements of license conditions, Technical Specifications and facility procedures..The circum-stances of the occurrence and the corrective actions were discussed with licensee representatives, and the following items were reviewed.

Control Room Operator Log.

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Computer printouts of reactor power, incore tilt, imbalance,

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rod insertion and fuel assemoly to average fuel assembly power ratios.

Facility normal operating precedures, abnormal operating pro-

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cedures and control rod operation procedure.

The sequence of events and licensee actions were as described below.

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Time Event / Action

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10:06 am Diamond Rod Centrol for "A&B" feedwater demands in manual for CRD breaker trip tests per SP 1303-4.1.

10:07 am Dropped rods 2, 3, 4, 5, 6, 8 and 9 in Group 3.

Reactor power reduced from 100%

to 40% F.P.

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10:23 am Determined that +3.64% tilt limit was ex-ceeded, when calculated incere tilt for ZW quadrant was +12.85%.

10:24 am Commenced trimming Group 3 rods.

10:27 am Initiated safety rods out bypass.

Partially inserted rods 1 and 7.

10:29 am Ccmmenced withdrawing dro:ced Group 3 rods one at a time to approximately 20% withdrawal.

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s10:30 am Commenced power reduction.

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10:43 am Verified shutdown margin-4.66%.

Comnenced

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shimming in Group 3 rod 1 and 7 one at a time.

11:07 am All Group 3 rods trimmed.

11:11 am Withdrawing Group 3 rods, while snimming Group 7 reds into core, to r.1:4tain 30%

power.

11:13 am Tilt in spec 9 +2.97%.

11:25 am All Group 3 safety rods fully withdrawn.

11:33 am Exceeded +3.64% tilt limit, when calculated incore tilt for WX quadrant was determined to be '6.23%.

12:03 pm Tiit in spec @ -2.33%.

12:C6 pm Ccmmencec slcwing increasing :cwer :: IC0%.

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T1e inspector' determined that the circumstances of the cccurrence and tne licensee's irrnediate corrective actions were as described above and that initial reporting requirements were met.

The in-spector found the licensee's actions acceptable, except as descrioed telow.

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Technical Specification Limiting Condition for Operation (LCO)

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3.5.2.2.a states that operation with more than one inoperable end...in the safety or regulating rod banks shall not be per-mitted. Additionally, Technical Scecification LCO 3.5.2.5.e states that safety rod limits (during power operation) are given in LCO 3.1.3.5, which requires safety rod groups to be fully withdrawn with certain exceptions.

10 CFR 50.36(b)(2)'

and Operating Precedure 1102-4 states that when an LC0 of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the techni-cal specification until the condition can be met; and the licensee shall notify the Ccmmission, review the matter, and record the results of the review, including the cause of the condition and the basis for corrective action taken to pre-clude recurrence.

Neither the above Technical Scecifications,

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10 CFR 50.36(b)(2), nor OP 1102-4 requires a time period within which the reactor shall be shutdown, when LC0's are not met.

Hcwever, OP 1102-4 requires Plant Superintendent notifi-cation and approval for continued operation on an ad hoc basis when an LCO'is not met.

(Technical Specifications in the STS format are more specific in this regard, as facility operation is allcwed to continue for only one hour when an LCO and conditions of associated action statements are not met.)

With respect to the occurrence described above, all safety group 3 rods were aligned to the same relative core positions one hour after the seven rods dropped, and all rods were fully-withdrawn in the next 20 minutes.

Licensee representatives stated that this occurrence would be reviewed as required, and appropriate measures taken to prevent recurrence would b."

described in the folicwup LER.

This item is "nresolved pending submission of the followup LER for this occui.1ce and com-pletion of the licensee's specific and generic corrective actions to prevent recurrence.

(289/78-14-04)

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Unresolved Items Unresolved items are matters about which more infor ation is required in or..c to ascertain whether they are accep'.able items, items of r

i noncompliance or a deviation. Unresolved items identified during

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l the inspection are discussed in Paragraphs 3.c(1), 3.c(2) and 9.

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Exit Interview

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i The inspector met with licensee representatives (denoted in Para-graph 1) at the conclusion of the inspection on June 15, 1978. The purpose, ccope and findings of the inspection were summarized.

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