IR 05000289/1981028

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IE Insp Rept 50-289/81-28 on 811003-1117.No Noncompliance Noted.Major Areas Inspected:Previous Insp Findings,Plant Operations During long-term Shutdown Including Facility Tours & Log & Record Reviews
ML20039C378
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 12/09/1981
From: Conte R, Fasano A, Haverkamp D, Koltay P, Nicholas H, Young F
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20039C369 List:
References
50-289-81-28, NUDOCS 8112290288
Download: ML20039C378 (19)


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

50-289/81-28 Docket No.

50-289

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Category C

License No.

DPR-50

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Priority

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Licensee :

Metropolitan Edison Company P.O. Box 480 Middle' town, Pennsylvania 17057 Facility Name: Three Mile Island _ Nuclear Station, Unit 1 Inspection at: M_iddletown, Pennsylvania Inspection conducted: October 3,1981 - November 17, 1981 Inspecto rs :

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D. Haverkamp, Senior Resident Inspector (TMI-1)

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R. Conte, Senior. Resident Inspector (TMI-2)

date signed A) SG 12$ % ]B P. Kolta.y (yeactorInspector dath signed

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H. Nic1olas, R

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, Resident Inspector (TMI-1)

date sig dd Approved by:

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A. F6sano, Chief, Three Mile Island Resident date signed Section, PB No.2 Inspection Summary:

Inspection on October 3,1981 - November 17,1981 (Report Number 50-298/81-28)

Areas Inspected: Routine safety inspection by resident and regional based inspectors (265 hours0.00307 days <br />0.0736 hours <br />4.381614e-4 weeks <br />1.008325e-4 months <br />) of licensee action on previous inspection findings; plant operations during long term shutdown including facility tours and log and record reviews; restart modification control program review; anchor bolt installation records review; periodic (monthly) report review; fire protection system surveillance review; and preoperational and startup test program review.

Results : No items of noncompliance were identified.

8112290288 B11211'

PDR ADOCK 05000289 G

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Detail s 1.

Persons Contacted General Public Utilities Nuclear Group (GPUNG)

B. Ballard, Manager TMI Quality Assurance (QA) Modification / Operations, Nuclear Assurance R. Barth, Engineer-II TMI-l

  • J. Colitz, Plant Engineering Director, TMI-l J. Faulkner, Planning and Scheduling Manager, Technical Functions R. Fenti QA Project Site Manager, Nuclear Assurance J. Flynn, Supervisor TMI-1, Startup and Test, Technical Functions J. Garrison, QA Engineer Assistant Senior ;II, Nuclear Assurance T. Hawkins, Manager Startup and Test TMI-1, Technical Functions
  • W. Heysek, QA Engineer III, Nuclear Assurance
  • N. Hollerbush, Engineer Assistant Senior II, Nuclear Assurance

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  • H. Hukill, Vice President and Director-TMI Unit 1 D. Jones, Civil / Structural QA Inspector, Nuclear Assurance S. Levin, Acting Maintenance and Coastruction Director, Maintenance and Construction
  • W. Miller, Nuclear Licensing Engineer, Technical Functions T. O' Connor, Lead Fire Protection Engineer TMI-l I. Porter, Supervisor Startup and Test TMI-1, Technical Functions J. Tietjen, Modification Construction Inspection Supervisor, Nuclear Assurance
  • R. Toole, Operations and Maintenance Director TMI-l
  • C. Smyth, Supervisor, TMI-1 Licensing, Technical Functions L. Zubey, Supervisor Contractor Services, Maintenance and Construction Catalytic _Inco rporated V. Haverstroh, Pipefitter General Foreman T. Reddington, Project Superintendent I. Silsbee, Piping Supervisor J. White, Journeyman Electrician G. Williams, Area Foreman The inspector also interviewed several other licensee employees during the inspection.

They included control room operators, maintenance personnel, engineering staff personnel and general office personnel.

  • denotes those present at the exit interview.

2.

Licensee Action on a Previous Inspection sinding (Closed) Unresolved Item 289/79-17-01 : Defective fire doors at control building elevatior.s 322 ft. and 338 ft.

The previous failures of the fire doors to auto iatically close were attributed to the installation of silicane foam electrical penetration fire barrier seals in the switch gear and cable spreading rooms, which altered the ventilation balance in these areas.

The licensee prepared ventilation balancing specificatioas SP110lX-515 and SP-492-D44692 to correct the ventilation problem.

The inspector verified that the doors now operate properly.

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Inspector Followup Item 289/79-17-02: Lack of monthly fire extinguisher inspections.

The inspector randomly reviewed the inspection tags on fire extinguishers located in the plant and verified that the licensee's monthly inspection program is now e f fective.

(Closed)

Inspector Followup Item 289/80-21-17:

Fire strategy procedures do not contain information for location and importance of vital equipment.

The inspector verified that the fire fighting pre-planning strategies have been revised to include a list of the safe chutdown equipment located within each area.

In addition, drawings of each fire area identify vital equipment locations.

(Closed)

Infraction 289/80-21-06:

Continuous fire watch was not maintained when the CO2 system for the cable spreading room was inoperable.

The licensee's corrective actions to this item are described in a letter dated November 26, 1930, serial TLL 587.

Whenever the requirements of Technical Specification 3.18.4.1 are not met, the licensee will maintain a continuous fire watch in the cable spreading room.

The inspector discussed these actions with licensee personnel and determined that the implementation of these actions is acceptable.

3.

Plant _ Operations During Long Term Shutdown a.

Plant Logs and Operating Records The inspector reviewed selected portions of the following plant procedures to determine the licensee established requirements in this area in preparation for a review of selected logs and records.

Administrative Procedure (AP) 1002, " Rules for the

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Protection of Employees Working on Electrical and Mechanical Apparatus," Revision 22 AP 1007, " Control of Records," Revision 4

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AP 1010, " Technical Specification Surveillance Program,"

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Revision 18 AP 1012, " Shift Relief and Log Entries," Revision 14

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AP 1013, " Bypass of Safety Functions and Jumper Control,"

Revision 8 AP 1016, " Operations Surveillance Program," Revision 13

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AP 1033, " Operating Memos and Standing Orders," Revision 2

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AP 1037, " Control of Caution and DN0 Tags," Revision 2

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AP 1044, " Event Review and Reporting Requirements,"

Revision 2

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The inspector reviewed the following plant logs and operat.ing s'

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Shift Foreman Log and Control Room Log Book

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Primary Auxiliary Operator's Log-Tour Readings,. Seconda'ry

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Auxiliary Operator's Log Sheets, and Auxiliary Operator

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Log Sheets - Out-Building Tour Unit 1 Operations Memo Book

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Shift Turnover Checklist

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Temporary Change Notice (TCN) Log Book

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Active Tagging Application Book

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Locked Valve Log

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ISI Tag Book

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Hight Order Book

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Do Not Operate and Caution Tag Log

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Plant logs and operating records were reviewed to verify the following items.

Log keeping practices and log book reviews are conducted

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in accordance with established administrative controls.

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Log entries involving abnormal conditions provide suf ficient

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detail to communicate equipment status,' lockout status, correction and restoratioq.

Operating orders do not conflict with Technical Specifi-

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cation (TS) requirements.

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Jumper log and tagging log entries do not conflict with TS requirements.

Problem identification reports confirm compliance with TS

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reporting and Limiting Condition for Operations (LCO)

requi rements.

Jumper / lifted lead / mechanical modificatf or. and tagging

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operations are conducted in confonnance with established administrative controls.

No items of noncompliance were identified.

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s0 urine the course o.' the ins [>ection" - the inspector conducted tod/s'~of the followlng plant 'a'reas.

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,' Control Rcom (da'ily)

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_Aurdllary. Bullding (October'9,14, 28 and November 5)

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ftiel Handli,ng Buil(ing (October 9, 20, 28 and November 5)

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Intermediate BuildJng,(October 6,13, 21 and November 16)

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Vit31' 5witchgeai(boms (October.7,15,19, 29)

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x Diesel Generato.tjSuih'ing (Octiober 16, 20, 30 and November 5,

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Ya rd Area (October 5, l'6,19, 21, 28 and November 10)

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Site Perimeter (October 8, 27 and November 6)

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The following observations / discussions / determinations were r'

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's Control room a.. 'unicators : Selected lighted annunciators

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were discussed with control room operators to verify that

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the reasons for them were understood and corrective

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action, if required, was being taken.

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inspection, the inspector verified that control room

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s4 manning requirements of 10 CFR 50.54 (k) and the Technical Specifications were being met.

In addition, the in.?ector t i)

observed shift turnovers to verify that continuity of

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system status was maintained.

The inspector periodically

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questioned shift personnel relative to their awareness of

plant conditions and knowledge of emergency procedures.

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Fire protection: The inspector verified that selected

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fire extinguishers were accessible and inspected on schedule, that fire alarm stations were unobstracted, and

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that adequate control over ignition sources and fire hazards was maintained,

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s Technical Speci fications : Through log review and direct

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observation during tours, the inspector verified compliance

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with selected Technical Specification LCO's during shutdown plant operation.

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-6-Plant housekeeping conditions : No unsatisfactory plant

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housekeeping conditions were observed which had not been identified by station personnel and for which corrective action had not been initiated, as necessary.

Monitoring instrumentation: The inspector verified that

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selected instruments were functional and indicated that parameters were within Technical Specification limits.

Valve positions : The inspector verified that selected

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valves were in the position or condition required by Technical Specifications for the applicable plant mode.

This verification included control board indication and field observation of valve positions.

Radiation controls: The inspector verified by observation

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that control point procedures and posting requirements were being followed.

The inspector identified no failures to properly post radiation and high radiation areas.

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Fluid leaks : No fluid leaks were observed which had not been identified by station personnel and for which corrective action had not been initiated, as necessary.

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Piping snubbers / restraints: Selected pipe hangers and seismic restraints were observed and no adverse conditions were noted.

Equipment tagging: The inspector selected plant components

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for which valid tagging requests were in effect and verified that the tags were in place and the equipment in the condition specified.

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Security:

During the course of these inspections, observations relative to protected and vital area security requirements were made, including access controls, boundary integrity, search, escort, and badging.

No adverse conditions were noted.

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Licensee meetings: The inspector frequently attended the Plan-of-the-Day (P0D) morning meetings and the daily status afternoon meetings held by licensee management and supervisory personnel.

The inspector observed the meetings to assess licensee evaluation of plant conditions, status and problems and to review the licensee's plans for conducting certain major plant operations and maintenance activities.

The inspector also attended bi-weekly project status meetings to assess licensee progress and difficulties related to plant modifications required for restart.

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-7-Acceptance criteria for the above items included inspector judgement and requirements of 10 CFR 50.54 (k), Regulatory Guide 1.114, Technical Specifications, and the following procedures.

AP 1002, " Rules for the Protection of Employees Working

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on Electrical and Mechanical Apparatus," Revision 22 AP 1008, " Good Housekeeping," Revision 7

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AP 1037, " Control of Caution and DN0 Tags," Revision 2

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No items of noncompliance were identified.

Restart Modification Control _ Program a.

Program Review Procedural controls for plant modifications were reviewed to verify incorporation of selected work control requirements of ANSI 18.7-1976 paragraph 5.2 and for familiarization with the licensee's modification control program es a basis for review of speci fic modi fications.

Selected sections of the following documents were reviewed.

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TMI-l Operational Quality Assurance Plan,Section V, Revision 9 Radiological Controls Procedure (RCP) 1651, "ALARA,"

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Revision 4 RCP 1651.1, "ALARA Pre-planning," Revision 1

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RCP 1651.2, "ALARA for Facility Design and Modification,"

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Administrative Procedure (AP) 1021 A/B, " Plant Modifications,"

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AP 1043, " Control of Plant Modifications," Draft Revision 2

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AP 1035, " Control of Transient Combustible Materials,"

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Revision 6

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AP 1047, "Startup and Test Manual," Revision 0 l

AP 1042, " Control of Welding," Revision 0

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AP 1020, " Cleanliness Requirements," Revision C

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Revision 3 AP 1026, " Corrective Maintenance and Machinery History,"

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Revision 12

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AP 1008, " Good Housekeeping," Revision 8 AP 1043, " Engineering Change Modifications," Revision 1

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AP 1054, " Control of Environmentally Qualified Safety

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Related Electrical Equipment," Revision 0 Maintenance Procedure (MP) 1410-Y-52, "Preoperational

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Startup Testing of Mechanical Equipment," Revision 1 MP 1410-Y-51, " General Procedure for Flushing Piping

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Systems," Revision 1

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MP 1410-Y-50, " General Procedure for Hydrostatic Testing of Systems and Components," Ravision 1

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MP 1420-EL-2, "Preoperational Startup Testing of Electrical Equipment," Revision 0

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MP 1420-FB-1, " Fire Barrier Penetration Seal Repair Installation," Revision 5

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MP 1412, " Control Receipt and Distribution of Weld Rod and Wire," Revision 3

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Engineering Management Procedure (EMP)-008, " Engineering Change Memorandum," Revision 8

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Engineering Procedure (EP)-015, " Design Change Notice,"

Revision 3

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EP-025, " As-Buil t Drawings," Revision 0 Engineering Standard (ES)-015, " Format and Content of

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Design Change Notice," Revision 1 b.

Speci fic Modi _f_i_ cation Review Documents associated with Task LM-1 (Saturation Temperature Indication / Alarm) were reviewed to verify the below listed items.

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Proper implementation of selected modification control procedures (noted above) in accordance with is 6.8.1

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NUREG 0680, TMI-l Restart Evaluation Report, and the licensee's TMI-l Restart Report Adequacy of post construction installation and preoperational

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testing

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Installation status of selected components by system walkdown Documents associated with Task LM-8A (Reactor Building Level Indication) were reviewed to verify the below listed items.

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Adequacy of appropriate document changes, including procedure revisions, which resulted from the modification

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Modification documents reflect applicable items of NUREG 0680 Selected sections of the following documents were reviewed.

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List of Engineering Change Memoranda (ECM's) by Task dated August 1981 Turnover Package (T0/P) No.129-1, which included ECM

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No. S-219, Revisions 0 through 7, for structural and electrical components of LM-1

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T0/P No.129-2, for Design Change Notices (DCN) Nos. 316, Revision 0 and 1; 370, Revision 0; 377,. Revision 0; and 385, Revision 0 for LM-1

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T0/P No.129-3 for LM-1

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T0/P No. 248-1, for ECM 248, Revision 0, for conduit supports and attachments for LM-1 Work Authorization Notice (WAN) No. 388, Revision 3, for

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ECM S-129, Revisions 0 through 7 with associated tie-in authorizations WAN No. 401, Revision 1 with associated tie-in authorization

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WAN No.131, Revision Ifor ECM S-144 and ECM 248

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Test Procedure (TP) 645/1, "TSAT (Saturation Temnerature)

Functional Test," Revision 0, for data taken August 26 -

September 6,1981

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-10-TP 345/l, "TSAT Indication Calibration," Revision 0, for

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data taken August 7-23, i981 Quality Assurance (QA) Audit Report No. S-TMI-81-03,

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l for inspection period February 17 - April 24,1981 c.

Findings (1) The status of LM-1, Saturation Temperature Indication /

Alarm, at the time of the inspection was that the operations and maintenance department was reviewing various turnover packages with most of the construction completed and same outstanding work items being resolved.

The Document / Drawing Change Verification and ECM Training Requirement attachments to AP 1043 were not completed.

However, the action that was to be certified by these documents was in progress on a " parallel path" in areas such as procedure revision and training.

During discussions with licensee representatives another modification, LM-8A, Reactor Building Level Indication, was used as an example for the completion of the Document /

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Drawing Change Verification form.

Two significant l

observations were made.

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The change verification form used for LM-8A was not as prescribed in AP 1043.

The form did not have identification of promulgating procedurc.

No emergency procedure change was required for

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LM-8A while it appeared that this instrument was to be used in the post-accident emergency situation.

However, further review determined that this modi-fication is being replaced by LM-8C.

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The improper use of documents with respect to AP 1043 was identified by the licensee's QA Audit No. S-TMI-81-03 during the period February 17 - April 24,1981.

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Finding No.16 addressed AP 1043, ECM Training Requirements were not being implemented.

Finding No. 24 identified that AP 1043 prescribed forms were not being used.

Finding No. 26 identi fied that AP 1043, Document / Drawing Change Verification form was not issued in a timely fashion.

The findings were in the process of being resolved.

Initial plant responses noted that document changes and training were conducted in a " parallel path" and that program changes would be issued for more effective implementation of AP 1043.

Discussions with U.censee representatives indicated that revised forms would be formally incorporated into the modification control progra,

e-11-The inspector indicated the above findings raised a question on the adequacy of licensee certification that appropriate documents were revised and adequate training was performed.

The licensee representative acknowledged the above and reiterated that the completion of the subject AP 1043 attachments are a final check on parallel path work in these areas.

The licensee also stated that the program revision to resolve the QA audit findings will be completed before restart.

The inspector stated it is expected that the proper AP 1043 attachments, in effect at the time of modification turnover / completion, will be completed for any restart modifications.

This item is unresolved pending completion of licensee action as stated above and further NRC review (289/81-28-01).

(2) The certification that design documents reflects safety evaluation items and restart report commitments was not accomplished due to priority review of the licensee's QA Audit in this area and followup to concerns identified during the course of the inspection.

This review for U4-1 will occur during the additional reviews of TMI-l restart modi fications.

The inspector had no further comments in this area.

5.

Anchor Bolt Installation Records a.

Backgro_und On October 13, 1981, a licensee representative reported an apparent deficiency in the quality of documentation on the installation of certain "Leibig" type safety anchor bolts.

A quality control inspector in the licensee's organization identified two similar documents recording the same installation data of the same anchor support plate positions.

This occurred for two separate Anchor Installation Documents (AID), Support No. l AXD-C68, position B, and Support No. l AXD-C3, position C for Modification RM-SC, Reactor Building Isolation.

For each AID position document, the original could be distinguished from the manually copied (handwritten) document (referenced below as the discrepent copy) as follows.

The original was marked with a stamp indicating modification

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task number, turnover package number and attachment number.

The discrepant copy did not have these markings.

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The original indicated a test (installation) torque on the anchor bolt in excess of the test acceptance criteria (130 ft-lb).

The discrepant copy indicated an acceptable test (installation) value for torque with no indication of a previous test failur.

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Installer and QC inspector signatures on the original were indicative of original handwriting while the discrepant copy signatures appeared false.

On October 14, 1981 the licensee representative wrote a Quality Deficiency Report (QDR) No. KMT-183-81 on this information and initiated a review to detennine the source and reason for the discrepant documents.

The initial findings of the licensee's review (internal memorandum SL-TMI-1-M&C-0020, dated October 16, 1981) identi fied the below sequence of events.

On December 17, 1980 the anchor for position C of Support No. l AXD-C3 was installed and the anchor failed the post installation torque test (maximum of 130 ft-lb).

The anchor for position B of Support No. l AXD-C68 similarly failed the post installation torque test on February 5,1981.

Field Questionnaires (Nos. R-486 and R-487) were issued with resolution to replace the subject anchors.

On May 5,1981 both anchors were replaced with acceptable post installation torque tests and these tests were observed by a quality control inspector.

During August 1981, various licensee representatives reviewed outstanding work items (punch list) for the pending hot functional test operations and the list indicated that the subject anchors still needed repair.

On August 22, 1981 contractor personnel replaced the gooo anchors from May 5,1981 with new anchors and post installation testing also indicated acceptable installation torque values.

However, during the documentation of the August 22, 1981 installation, a contractor individual misunderstood his foreman's instructions and manually (handwritten) copied (apparently from a photostatic copy of the original) previously recorded information for the three unaffected anchor position installations on each support plate, including installer and QC signatures.

Further, the August 22 data was written for the anchor position columns that previously reflected the torque test failure.

The discrepant AID's (with original handwriting) were then forwarded for routine review and incorporation into the turnover package.

The initial conclusion of the licensee's review was that the handwritten copying was an honest mistake with no intention to subvert or bypass the licensee's quality control system.

In addition to the above review, on October 14, 1981 the licensee representative retested the torque values for the August 22, 1981 installation on the subject anchors and the resul ts were satisfactory.

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Review As a result of the licensee's initial findings in this area, a review was initiated by the inspector to verify the below listed items.

Licensee findings on the circumstances leading to the

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production of the discrepant documents on AID Nos, l AXD-C68 and 1 AXD-C3

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Proper documentation of implementation of the maintenance procedure for the subject anchors in accordance with Technical Specification (TS) 6.8.1

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Proper implementation of the maintenance procedure in accordance with TS 6.8.1 by selective witnessing of the installation of "Leibig" type safety anchors

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Proper documentation of QC inspection activities associated with the subject anchors in accordance with 10 CFR 50, Appendix B, Criterion XVII Selected sections of the following documents were reviewed.

Maintenance Procedure 1410-Y-61, Revision 1, "Leibig

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Safety Bolt-Wedge Type Expansion Concrete Anchor Installation Procedure" Anchor Installation Document (AID) for Support Plate

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No. l AXD-C68, dated May 5,1981, and the Support Plate No. l AXD-C3, dated May 5,1981, for Modi fication RM-5C Reactor Building Isolation (originals)

(Discrepant) copies of AID's for Support Plate No. l AXD-C68,

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dated February 5,1981, and Support Plate No l AXD-C2, dated December 27, 1980

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Selected AID's from Modification Package RM-SC

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Quality Deficiency Report (QDR) No. KMT-183-81, dated October 14, 1981

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Plant Inspection Report (PIR) No. CS/31439/81, dated October 14, 1981 PIR No. CS/30096/81, dated February 3,1981

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PIR No. CS/30499/81, dated May 5,1981 PIR No. CS/30210/81, dated December 17, 1980

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-14-GPU Service Corporation Specification 1101X-53, Revision 2,

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" Furnishing and Installation of Concrete Expansion Anchors" In addition to conducting interviews with personnel involved, on October 21, 1981, the inspector witnessed portions of the installation of Leibig anchor bolts for ECM 215, Revision 0, Emergency Feedwater Backup Air Supply.

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Findings The inspector verified the sequence of events as described above (paragraph 5.a).

The erroneous documentation apparently was not an attempt to subvert or bypass the licensee's quality control system.

As discussed with licensee representatives, the August 22, 1981 installation of the subject anchor bolts was to be documented on new or separate AID sheets denoting new data for the anchor position of the support plate.

At the close of the inspection, internal responses to the QDR were under review by the licensee,and,therefore, corrective actions were not finalized.

Accordingly, this area is unresolved pending completion of licensee action as noted above and subsequent NRC review (289/81-28-02).

6.

In-Office Revi_ew of_ Periodic Repo_rts_

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The inspector reviewed the periodic reports listed below, which were submitted to the NRC Region I office, to verify that the reports included required information and that test results and/or supporting information discussed in the reports were consistent with design predictions and performance specifications, as applicable.

The reports were also reviewed to ascertain whether planned corrective action was adequate for resolution of identified problems, where applicable, and to determine whether any information contained ii the report should be classified as an Abnormal Occurrence.

The following TMI-l periodic reports were reviewed.

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January Operating Report, dated Febraury 13, 1981 February Operating Report, dated March 13, 1981

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March Operating Report, dated April 15, 1981 April Operating Report, dated May 15, 1981

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May Operating Report, dated June 15, 1981

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June Operating Report, dated July 16, 1981 The above reports were closed based on satisfactory in-office review.

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Fire Protection Systems Surveillance The inspector randomly selected and reviewed test results of the following procedures requiring surveillance of the fire protection equipment in accordance with Technical Specification Section 3.18.

Surveillance Procedure (SP) 3303-R2, " Fire Pump Capacity

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Testing," Revision 1.

The inspector examined the results of tests performed on February 11, 1980.

SP 3303-A2, " Fire System Main Header Flush and Loop Test

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Procedure," Revision 2.

The inspector examined the results of tests performed on February 15, 1980 and September 10, 1981.

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SP 1303-12.8A, " Fire Protection Instrumentation Functional Test, Control Building El. 355," Revision 11.

The inspector examined the results of tests performed on June 15, 1980 and October 4, 1980.

SP 1303-12.8B, " Fire Protection Instrumentation Functional

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Test, Control Building El. 338," Revision 3.

The inspector examined the results of tests performed on April 18, 1980, October 29, 1980 and April 17, 1981.

SP 3303-M1, " Fire Pumps Periodic Operation," Revision 9.

The

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inspector examined results of fire pump tests performed in 1981.

No items of noncompliance were identified.

8.

Preoperational and Startup Test Program a.

Overall Res_ tart Program The inspector met with the licensee's representatives for discussions of the preoperational testing portion of the TMI-l restart test program.

Interviews and meetings with the startup group included dicussions and reviews in the following areas.

Test program implementation

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Results of the preliminary hot functional test sequence

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Modification, completion and system turnover to startup and test Preparations for final heatup and startup phase

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Remaining test procedures to be received and reviewed by the NRC Region I office

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Test procedure reviews, verifications and test results evaluation

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Findings As a result of discussions with management and the startup group, interviews with licensee personnel, and examination, review and evaluation of test results of completed tests, the inspector verified that the licensee has met the NRC pre-operational test program requirements and appears to have adequate administrative and management controls for the implementation of the required preoperational testing.

b.

Preoperational Test Procedure Verification The following test procedures were reviewed to verify that adequate testing is planned to satisfy regulatory guidance and licensee commitments.

Test Procedure (TP) 247/1, " Industrial Coolers Functional

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Test," Revision 0 TP 654/1, " Main Steam Safeties Acoustic Monitor Functional

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Test," Revision 0

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TP 651/1, " Intermediate Closed Cooling System Flow Test,"

Revision 0 TP 233/1, " Emergency Feed Water System Functional Test,"

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Revision 0

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TP 233/2, "Bnergency Feed Water Pumps 48-Hour Run,"

Revision 0 TP 346/1, "Incore Thermocouple Checkout and Calibration,"

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Revision 0 TP 376/1, " Reactor Protection System Trip on Turbine /Feedwater

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l Calibration and Logic Verification," Revision 0

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TP 376/2, " Reactor Protection System Trip on Turbine /Feedwater Input," Revision 0 TP 426/2, "4 KV E.S. Bus Undervoltage Relays," Revision 0

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TP 664/1, "PORV Flow Indication Functional Test," Revision 0

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TP 664/2, " Pressurizer Operation Test," Revision 0

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TP 677/1, "RCS Post Accident Sampling Functional Test,"

Revision 0

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The inspector verified that the licensee had a procedure written, reviewed and approved.

Management approval was in accordance with established licensee procedures and test objectives were consistent with test titles.

No discrepancies were noted in the review of these procedures and the inspector had no further questions at this time.

c.

Preoperational Test Results Evaluation The following test proceaures were reviewed to ascertain whether uniform criteria are being applied for evaluating completed preoperational tests to assure their technical and administrative adequacy.

TP 233/1, Revision 0 (test results evaluation approved

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August 24, 1981)

TP 233/2, Revision 0 (test results evaluation approved

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August 24, 1981)

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TP 247/1, Revision 0 (test -results evaluation approved October 13, 1981)

TP 346/1, Revision 0 (test results evaluation approved

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August 24, 1981)

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TP 376/1, Revision 0 (test results evaluation approved August 24, 1981)

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TP 376/2, Revision 0 (test results evaluation approved August 24, 1981)

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TP 426/2, Revision 0 (test results evaluation approved August 24, 1981)

TP 651/l, Revision 0 (test results evaluation approved

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October 13, 1981)

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TP 654/1, Revision 0 (test results evaluation approved October 13, 1981)

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TP 664/1, Revision 0 (test results evaluation approved October 13, 1981)

TP 664/2, Revision 0 (test results evaluation approved

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October 13, 1981)

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-18-TP 677/1, Revision 0 (test results evaluation approved

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September 30, 1981)

Findings The inspector reviewed the test results and verification of licensee evaluation of test results by the following methods.

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Review of test changes

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Review of test exceptions

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Review of test deficiencies

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Review of "As-Run' copy of test proceaure Review of QA inspection records

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Review of test results evaluations and approvals

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No discrepancies were noted in the review of test results, except as discussed below.

(1 ) TP 346/1, "Incore Thermocouple Checkout and Calibration,"

Revision 0 has two test exceptions and eight test deficiencies to be resolved at a later date when testing resumes.

(2) TP 664/2, " Pressurizer Operation Test," Revision 0, had two test deficiencies to be resolved during final hot functional testing and one deficiency to be included in controlling procedure TP 800/1 for resolution.

(3) TP 677/1, "RCS Post Accident Sampling Test," Revision 0, was unsatisfactory and will be repeated.

The retest is

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tentatively to be included in controlling procedure TP 700/1.

Licensee resolution of the above test exceptions and deficiencies will be reviewed during a subsequent NRC inspection (289/81-28-03).

9.

Unresolved Items i

Unresolved items are matters about which more information is required to clarify whether they are acceptable items, items of noncompliance, or deviations.

Two unresolved items are addressed in paragraphs 4.c.(1) and 5.c.

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-19-10. Exit Interview Meetings were held periodically with senior facility management during the course of the inspection to discuss the inspection scope and findings.

The inspector met with the licensee representatives (denoted in paragraph 1) at the conclusion of tne inspection on November 17, 1981, and summarized the purpose and scope of the inspection and the findings.

The licensee representatives acknowledged the findings.

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