IR 05000289/1980017

IE Insp Rept 50-289/80-17 on 800620-0710.No Noncompliance Noted.Major Areas Inspected:Work Activities & Records Associated W/Unit 1 Restart Program,Tendon Surveillance Program & Fire Protection Program

ML19351D354
Person / Time
Site:	Three Mile Island
Issue date:	08/20/1980
From:	Ebneter S, Gage L, Sanders W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19351D352	List: IR 05000289/1980017 ML19351D351
References
50-289-80-17, NUDOCS 8010100021
Download: ML19351D354 (12)

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.

50-289/80-17

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Docket No.

50-289 License No. DPR-50 Priority

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Category C

Licensee:

Metropolitan Edison Company

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P.O. Box 542 Reading, Pennsylvania Facility Name:

Three Mile Island, Unit 1

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inspection at:

Middletown, Pennsylvania j

Inspection conducted:

June 20-July 10, 1980 Inspectors:

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/f2o L. Gage, R'eactof Inspector date' signed WW kAJ J/+ /r/

W. Sanders, Reactor Inspector

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fhho P. Koltay/ Reactor Inspector cite tigned

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R. Paq71no, Reactor Inspector citte 'si gned de bb et (bv)

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A.Vareld, Red'ctorlnspector afte/ signed S. Ebneter S.Synetr, Chief,ESS#2,RCESBranch date signed Approved by:

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bneter, Chief, Engineering Support date' signed

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Section #2, RC&ES Brhnch s...

Inspection Summary: Inspection on June 20-July 10, 1980 (Report No. 50-289/80-17)

Areas Inspected:

Routine, unannounced inspection by regional-based inspectors j

of work activities aiid records associated with the Unit 1 Restart Program as well as certain previously unresolved items affecting(Task RM-1), the fire pro-Unit 1, including:

the tendon surveillance program, the butt-splice program tection program (Task NM-40), the high-pressure injection cross-connect modifi-cation (Task RM-14), qualifications of QC inspectors, and QA site audits.

The inspection involved 107 inspection hours on site by five NRC regional-based inspectors and one Section Chief.

Resul ts:

No item of noncompliance was identified.

Region I Form 12 (Rev. April 77)

8010100 i

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DETAILS 1.

Persons Contacted GPUSC N.

Kazanus, QA Manager J. Wright, QC Manager J. Fornicola, 0QA Supervisor D. Cowfer, Manager, Materials Technology

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Metropolitan Edison Company

• W. Shomaker, Quality Control

• G. Troffer, Unit 1 Restart Deputy Manager j

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Porter, Unit 1 Restart

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Shaffer, Unit 1 Restart T. O' Conner, Lead Fire Protection Engineer Gilbert Associates, Inc. (GAI)

C. Brumback, Lead Dfaftsman C. Musser, Responsible Engineer R. Angus, Fire Protection Engineer

• W. Acker, Construction / Unit 1 Restart U.S. Nuclear Regulatory Commission

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A. Fasano, Chief, Site Operations Section, TMI

• 0. Haverkamp, Senior Resident Inspector, TMI-1

• Denotes personnel present at exit interview.

2.

Licensae Action on Previous Inspection Findings a.

(Unresolved) Item of Concern 80-04-02:

Fabrication of Butt Splices (Tasks RM-1, RM-4, and LM-8A)

The referenced inspection report identified the previously fabricated butt splices as an item of concern because of the method used for producing the splice, the training of craft personnel, and the fire hazards analysis.

The licensee has agreed to replace the heat-shrink-insulated butt splices in accordance with a revised procedure and additional quality controls as specified in SECM-138.

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The inspector reviewed SECM-138, Revision 0, dated June 4, 1980 for the RM-1 task.

Pages 2 and 3 of attachment 8 to the SECM provide dimensional limits for the positioning of the butt splice.

The information presented allows a center-to-end distance of two to three inches and an overall splice length of four to six inches.

Vendor instruction sheet 1050 calls for a minimum two inch seal length which might not be met if worst case center-to-end distance was only two inches.

The licensee agreed to revise the ECM to reflect the minimum requirements in the vendor instruction sheet.

The inspector noted that the fire hazards analysis report, dated June 4,1980, did not address the combustible red sealant material incor-porated in the butt splice.

The licensee will review his fire hazards analysis report and determine if the additional combustible load produced by the use of the red sealant material is of any significance.

This item is considered to be unresolved, pending an NRC review of the revised SECM, the fire hazards analysis, and the licensee training during a subsequent inspection.

(80-04-02)

b.

(Closed) Unresolved Item 80-09-02:

Certification of Split Shims used in Tendon Surveillance Program The referenced inspection report identified the split shims that were supplied by VSL for the tendon surveillance program as requiring a material analysis to verify their certification.

The inspector reviewed the documentation relative to the material certification, the chemical and physical analyses of the shims per-formed for VSL and the engineering. evaluation performed by the licensee.

No items of noncompliance were identified.

c.

(Closed) Item of Concern 80-06-06:

Possible Contamination of Weld MU-

The referenced report identified a blue paint marking and two kinds of tape on 2" stainless piping in the area of weld MU-45 in the high-pressure safety-injection cross-connection modification. The inspector inquired if these materials met the requirements of GPU Specification 3064-A007 Section 3.9 for the control of contaminants.

The licensee provided chemical certification from the manufacturer of the metal marker and the manufacturer of the tape to show that he met the requirements of the specification.

No items of noncompliance were identified.

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d.

(Closed) Unresolved Item 77-29-02:

Design for Installation of Cable-Penetration Seals The referenced inspection report identified the necessity of incorporating a design change for the installation of cable penetration seals in the applicable procedures and drawings.

The inspector verified that (1) the licensee issued a Maintenance Procedure, MP 1420-FB-1 for the resealing of electrical cable pene-tration using silicone foam and, (2) design changes have been included in the applicable drawings.

No items of noncompliance were identified.

e.

(Closed) Unresolved Item 79-19-01:

Automatic Suppression System for the Auxiliary Diesel Generators The referenced inspection report discussed the fire protection systems protecting the auxiliary diesel generators.

It was determined by the licensee and the licensee's insurance carrier, that the existing automatic detection system, portable extinguishers and yard hydrants provide adequate protection without an automatic fire-suppression system.

No items of noncompliance were identified.

f.

(Unresolved) Unresolved Item 79-17-01:

Fire Door Operation The referenced inspection report discussed the failure of the fire doors at elevations 322' and 338' of the control building, to auto-matica11y close.

The inspector reviewed the licensee's analysis and solution to the problem.

The licensee's analysis indicated that, due tc the installation of silicone-foam electrical penetration seals in the switchgear and cable spreading rooms, the ventilation balance in these areas was altered.

This resulted in door closure problems.

The inspector verified that the licensee initiated an administrative control by conducting a daily inspection of the fire doors in accordance with Procedure 1301-1, " Shift / Daily Checks, Fire Door Data Sheet No. 3".

The licensee also prepared Ventilation Balancing Specifications SP-1101X-515 and SP-492-044692 to correct the ventilation problem.

This item is considered to be unresolved, pending a review by an NRC inspector during a subsequent inspection that the specifications have been implemented.

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(Closed) Unresolved Item 79-17-03:

" Hands On" Training for Fire Brigade Members The referenced inspection report discussed the lack of full partici-pation in " hands on" training in the use of fire protection equipment by members of the fire brigade attending fire protection training class.

The inspector reviewed the outlines for the basic fire brigade train-ing course prepared by the licensee.

The inspector verified that the outlines satisfy the guidelines of Section C.2, Administrative Procedures, Controls and Fire Brigade, of the NRC Branch Technical Position 9.5-1 and of the supplemental guidance provided in Attachment No. 2 of the Nuclear Plant Fire Protection Functional Responsibilities.

The inspector

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verified that the licensee's instructor delivered the course material in accordance with the outlines.

The licensee stated that " hands on" equipment training for fire brigade members will be accomplished during July and August 1980, and will include:

the use of various types of portable extinguishers, discharge of water through fire hoses, extinguishment of small pan fires and bonfires using extinguishers and fire hose, and use of self-contained breathing equipment and protective clothing.

The licensee stated that practice sessions on the proper method of fighting various types of fires of similar magnitude and complexity as those which could occur at the plant will be scheduled at the York County Fire School, during July and August, 1980.

The inspector reviewed the following precedures and sections of the licensee's Emergency Plan for TMI Unit 1, Revision 2, dated June 1980:

4.5.2.2 Fire Fighting Organization

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4.6.1 Emergency Notification of Offsite Agencies

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4.8.1.1 Training

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4.8.1.2 Drills and Exercises

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Unit 1 Emergency Procedure 1202-31, Fire, September 1978

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Procedure 1004.21, Fire Emergency, October 1979 Procedure 1004.1, Unusual Event

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AP 1038, Fire Protection Program Plan, Revision 2, June 1980

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The inspector verified that the licensee developed details for train-ing and fire fighting procedures which cover:

(1) Actions to be taken by the fire brigade.

(2) Coordination of fire fighting activities with offsite fire departments.

(3) Actions to be taken by plant superintendent and security guards after notification of fire.

Instructions for plant operators and general plant personnel during a fire.

(4) Requirement for announced and unannounced drills.

(5) Requirement that at least one drill per year be performed on a

"back shift" for each fire brigade.

Requirement that local offsite fire department participate in at least one annual drill.

No items of noncompliance were identified.

h.

(Closed) Items of Concern:

80-06-01, 80-11-01, and 80-11-02: Identi-fication of ECMs for Fire Protection Program as Being of Safety Significance The electrical portion of ECM 063 (fire detectors) and ECM 064 (halon system) were identified as "important to safety" by the licensee.

However, as discussed in the referenced inspection reports, the licensee indicated "QA - not rc~1 ired" on the front pages of the ECMs.

The inspector verified that the licensee has now issued attachments 190-193 to ECM 063 and attachments 68-71 to ECM 064, dated May 20, 1980, requiring quality-control surveillance during the installation of both ECMs.

No items of noncompliance were identified.

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(Closed) Item of Concern 80-06-02:

Critique of Licensee Fire Drill The referenced inspection report identified apparent inadequacies in the licensee's performance during a fire drill he conducted on March 8, 1980.

The inspector verified that the licensee has taken corrective actions, including:

class-room instructions, practical training, placement of additional radio equipment and re-evaluation of Security and HP personnel actions.

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No items of noncompliance were identified.

3.

High-Pressure Injection Cross-Connect Modification a.

Radiography Eight welds (MU-55, MU-56, MU-57-6, MU-58-6, MU-69, MU-70, MU-76 and MU-77) were randomly selected from the high pressure injection cross-connect system.

The inspector reviewed the radiographs for compliance to the requirements of the licensee's specification 3064-A-007, ANSI B.31.7, and Nuclear Energy Services Inc. "Non Destructive Testing l

Procedure XR-1-NP".

It was noted that each of the radiograph examina-tions consisted of four double film exposures 90o apart using type M film with a No. 10 Penetrameter placed on the film side of each exposure.

Each of the films reviewed had the required reader sheets contained with the film in the designated envelopes.

The inspector examined the interpretation records and technique sheets, including the required system and weld identification, material thickness and diameter, type of radiation source, film type, number of films in cassett for each exposure, source-to-film distance, type and thickness of screens, identity of welders, radiographers, reviewers and description of evaluation results.

The radiographs were reviewed using a high intensity viewer to examine the film for required identification, required definition, radiographic quality, or defects such as mechanical, chemical or other blemishes such as fogging, process marks, and scratches that could cause a loss of detail or mask the area of interest.

During the examination of the films for defects, random checks were made of the required density in the area of interest.

This was done, using an electronic densitometer which was calibrated by the inspector using a standard density strip chart.

The remainder of the radiograph-inspection consisted of selection and placement of the penetrameter and review of radiographs for apparent defects.

No items of noncompliance were identified.

b.

Welder Performance Qualifications The inspector reviewed the performance qualification records for seven welders who performed welding on the high pressure injection system modification and were identified with the review of radiographs described in paragraph 3.1.

The records were examined for compliance to the ASME Section IX in the areas of process selected, weld procedure used, type of weld joint, position qualified, material used for test, filler metal, size and thickness qualified and type of test used for qualification.

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inspector noted that bend tests were used as verification tests.

The examined welders' records are listed by their individual identifi-cation number and the applicable procedure:

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Identification No.

Procedure 263 SP4200 S/S(N) 101 GTAW

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SP4200S/S(N 102A GTAW & SMAW

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058 SP4200 S/S(N 101 GTAW

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SP4200 S/S(N 102 GTAW & SMAW

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154 SP4200 S/S(N 101 GTAW

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SP4200 S/S(N 102A GTAW & SMAW

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512 SP4200S/S(N 102A GTAW & SMAW

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SP4200 S/S(N) 101

- GTAW 157 SP4200 S/S(N) 101

- GTAW SP4200 S/S(N) 102A - GTAW & SMAW 074 SP4200 S/S(N) 101 GTAW

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SP4200 S/S(N) 102A - GTAW & SMAW 216 SP4200 S/S(N) 102A GTAW & SMAW

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No items of noncompliance were identified.

c.

Weld-Procedure Specifications The inspector examined two of the welding procedures used in the welding of the high-pressure injection system modification for com-pliance to the essential variables and welding parameters required by ASME Section IX. The inspector reviewed the data related to the welding of the test coupons, testing of tha specimens as required by the code and recording the data and test results in the Procedure Qualification Record. The specifications reviewed were SP4200 S/S(N)

102A and SP4200 S/S(N) 101.

No items of noncompliance were identified.

d.

Control of Welding Materials The inspector examined licensee Procedure GP 3805, Revision 1, which defines a system of control during receipt, storage, and distribution of filler metals in accordance with ASME Code,Section II - Part C, AWS filler metal specifications and manufacturer's specifications. A walk-through inspection was made of the following areas:

Receipt and control of filler metals.

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Retention of required documentation.

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Release of electrodes and weld material.

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Storage ovens material separation.

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Oven temperature and calibration of ovens.

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Return of unused electrodes.

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No items of noncompliance were identified.

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General Observations i

The inspector performed a walk-through inspection inside the primary containment to observe work activities in progress, status, and com-

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pleted work associated with the high-pressure injection system modifi-

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cation. The piping system was examined for visual defects and com-

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pliance with regulatory requirements.

Particular note was taken of

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the welds with respect to surface condition and merging of the weld to the base material for subsequent preservice and inservice (NDE) examinations.

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Gilbert Associates, Inc. drawing C-32-661-1A-5 titled "Make-up and

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Purification" was used to examine the system layout and weld locations.

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No items of noncompliance were identified.

Tendon Surveillance Program

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i The inspector performed a record review of the incomplete in-process data l

sheets for testing, inspection and retensioning on five vertical tendons and nine of ten hoop tendons.

The inspector referenced the following inspecting criteria:

Tendon Surveillance Specification SP130 1-9.1, Revision 3.

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Reg. Guide 1.35, Revision 1, required by Technical Specifications.

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t VSL Quality Assurance Program.

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The review included data sheets and supporting sketches to meet criteria identified in Surveillance Procedure'1301-9.1:

r Data Sheet #2, Prestress Force Confirmation Test, Hoop Tendons.

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Data Sheet #3, Prestress Force Confirmation Test, Vertical Tendons.

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Tendon Detensioning Ram Calibration.

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Data Sheet #7, Anchorage Assembly Surveillance Inspection.

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This review identified the removal of one wire each from Vertical Tendon

1. V-18 and Hoop Tendon #H-46-030.

These wires were observed, after removal, adequately coiled and stored with no visible oxidation. The licensee will ship these wires to a qualified laboratory for physical testing as required by surveillance procedure and Reg. Guide 1.35 upon completion of the tendon surveillance.

No items of noncompliance were identified.

5.

Hydrogen Recombiner (Task RM-12)

The inspector observed the civil / structural work and noted that it was completed. He reviewed the licensee's verification of criteria established in:

Drawing E-901-33-001, GAI Specification SP-5585, " Specification for Structural Steel", referenced ASTM and AISC standards for bolting and structural steel, and procedure #1410-Y-54 for anchor bolt torqueing.

His review included the following licensee QC records:

Inspection Report

Date

Description

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S1-682

3/10/80

NCR on anchor bolt projection - cleared.

-763

4/4/80

Witnesscd/ tested dry pack and grout.

-777

4/24/80

Witnessed hole reaming / expansion anchors.

-780

4/28/80

Witnessed installation of expansion anchors.

-782

4/29/80

Witnessed anchor bolt surveillance per NRC

Bulletin 79-02.

-787

4/30/80

Witnessed anchor bolt torqueing and checking.

-791

4/30/80

Witnessed anchor bolt torqueing and checking.

-794

5/1/80

Witnessed anchor bolt length of bolt inspected.

-802

5/6/80

Witnessed drilling holes / expansion anchors /

pipe, hinges.

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5/8/80

Witnessed torqueing anchor bolts.

-812

5/9/80

Witnessed and tested ccncrete for console

pads.

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5/14/80

Inspection-curing concrete for console pads.

-818

5/15/80

Inspection-chipped concrete / group prep.

No items of noncompliance were identified.

6.

Fire Protection (Task NM-40): Modifications to the Manual Hose Stations

and Fire Dampers

The inspector selected hose stations at locations at elevations 339', 357'

and 380' in the Control Building, and in the heat exchanger vault of the

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Auxiliary Building to verify,by direct observation, the modifications required

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by ECM-S-067 and paragraph 3.1.2 of the Safety Evaluation Report for Fire

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Protection.

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The inspector made random selections of installed fire dampers to verify

that the installation has been completed in accordance with drawings C-302,

C-311 and E-311 of ECM-5-086 and -087 and paragraph 3.1.7 of the Safety

Evaluation Report.

No items of noncompliance were identified.

7.

Review of I.E. Circulars

a.

Circular 78-CI-18, U.L. Fire Test

The inspector verified that the licensee reviewed the circular and

issued an appropriate response dated December 19, 1979.

b.

Circular 78-CI-13, Diesel Fire Pump Relays

The inspector verified that the licensee's diesel engine model number

is different from the models identified in the circular and that,

therefore, this circular is not applicable to TMI, Unit 1.

No items of noncompliance were identified.

8.

Qualification of QC Inspectors

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The inspector selected two names from the licensee's list of QC inspectors,

to verify their credentials.

He selected inspectors who are presently

working on on-going Task NM-40, performing electrical inspections of fire

protection system modifications. The licensee stated that these personnel

were qualified as Level II electrical inspectors in accordance with the

qualification requirements of ANSI N45.2.6-1978.

(The licensee's " Operational

QA Plan, Revision 8, dated April 18. 1980, commits him to NRC Regulatory

Guide 1.58, which in turn commits him to~the ANSI document.)

The inspector reviewed the education, training, and experience documenta-

tion filed for the two inspectors.

He concluded that they met the level II

requirements.

The inspector the, reviewed the electrical modifications to determine if

the inspectors possessed adequate credentials for the work they were performing.

He reviewed the inspection check lists in S-ECM-064, Revision 1 and S-ECM-

063, Revision 2. and concluded that their credentials were adequate.

No items of noncompliance were identified.

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9.

QA Site Audits

The inspector reviewed the documentation of the auditing activities conducted

by the licensee's site QA Auditing Group to determine if the scheduling and

frequency of the audits satisfied the licensee's program requirements.

The 1lcensee's " Operational QA Plan," Revision 8, paragraph 9.2.1, states

that " Audits shall be performed in accordance with pre-established written

procedures... (and)...shall be regularly scheduled... ".

The inspector reviewed licensee procedure 7-18-01, Revision 5, " Quality

Assurance Audits," which requires the establishment of r program of site

audits, and establishing and updating a site audit schedule.

The inspector then reviewed licensee memo dated March 22, 1980, from N.

Kazanas to R. Arnold, which documented the present audit sched/e.

The inspector then reviewed two recent audit reports to determine if they

addressed the TMI Unit 1 Restart Modification Program at the site:

S-TMI-

79-09, dated February 19, 1980 and S-TMI-80-08. dated April 12, 1980.

The inspector then reviewed the list of recipients of the audit reports,

which included the Senior Vice President of Metropolitan Edison Company,

the Director of TMI, Unit 1 and the Manager of Quality Assurance.

No items of noncompliance were identified.

10. Unresolved Items

Unresolved items are matters about which more information is required in

order to ascertain whether they are acceptable items, items of noncompliance,

or deviations. Unresolved items reviewed during this inspection are discussed

in paragraph 2.

11.

Exit Interview

The inspectors met with the licensee representatives (denoted in paragraph

1) at the conclusion of the inspection on July 10, 1980. The inspector

sumarized the purpose and scope of the inspection and the findings. The

licensee acknowledged the findings.

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