IR 05000289/1985015

Insp Rept 50-289/85-15 on 850415-19.No Violations or Deviations Noted.Major Areas Inspected:Verification of Completion of Specific Items of NRC Certification Process

ML20127J509
Person / Time
Site:	Three Mile Island
Issue date:	06/04/1985
From:	Anderson C, Finkel A, Paolino R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20127J504	List: IR 05000289/1985015 ML20127J501
References
50-289-85-15, NUDOCS 8506260659
Download: ML20127J509 (12)

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U U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-15 Docket N ,

License No. OPR-50 Priority --

Category C Licensee: GPU Nuclear Corporation

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P. O. Box 480-Middletown, Pennsylvania 17057 Facility Name: Three Mile Island Nuclear Station, Unit 1 Inspection At: Middletown, Pennsylvania Inspection Conducted: April 15-19, 1985 Inspectors: O'

A. E. F ke Lea Reactor Engineer date M s.za sf R. o o Lead Reactor Engineer da e Approved by: O 87f ,

C. J/ Anderson, Chief 'date Plant Systems dection, DRS

< Inspection Summary: Inspection on April 15-19, 1985 (Report No. 50-289/85-15)

Areas Inspected: Routine, unannounced inspection to verify completion of i

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specific items of the NRC's certification process. The inspection involved 82 inspection hours on site by two region based inspector Results: No violations or deviations were identified.

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DETAILS 1.0 Persons Contacted 1.1 General Public Utility-Nuclear (GPUN)

• B. E. Ballard, Sr., Manager TMI QA Modification / Operations

• C. D. Brumlock, M&C Document Control Administration P. Djoka, I&C Engineer

• E. Eisen, Project Engineer

• T. Faulkner, Manager, Planning-M&C

• C. E. Hartman, TMI-1 Plant Engineering Manger

• T. M. Hawkins, Manager, Startup & Test

• C. L. Incorvati, TMI-1 Audit Supervisor

• R. Knight, Licensing Engineer J. Marsden, QA Engineering Manager

• R. E. Neidig, Communications R. N. Prabhakar, QC Manager *

• C. W. Smyth, Licensing Manager TMI-1

• M. G. Snyder, P. M. Manager R. J. O'Toole, O&M Director U.S. Nuclear Regulatory Commission

• R. J. Conte, Senior Resident Inspector

• F. Young,' Resident Inspector

• denotes personnel present at exit interview ,

2.0 Licensee Action On Previously Identified Inspection Findings 2.1 (Closed) LER 84-LO-05 pertaining to seismic qualification of Differential Relays in the Emergency Diesel Generator Control Circuits. The differential relays operate a lockout relay which trips and locks out the diesel generator breaker ano diesel engine in the event of an electrical fault within the generator winding Incorrect operation during a seismic event could result in both diesel generators being unavailable. The licensee had reported that the relay supplier was unable to provide documentation to show that the relays were seismically qualified and that the manufacturer does not recommend the relays for seismic service. Licensee corrective action is to replace the unqualified differential relay with one whose qualification characteristics are know The inspector verified replacement of the unqualified relays with a seismically qualified solid state differential relay Model N ITE-87M, manufactured by Brown-Boveri Electri ._

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Performance Tests indicate the solid state differential relay Model No. ITE-87M electrically and mechanically comply with manufacturer's

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specification This item is close .2 (Closed) LER 84-LO-02 pertaining to partial actuation during ESAS maintenance testing on one channel with an unknown failed relay in another channel. Failure was attributed to the binding of the XKPM-10 magnet kit and armature rod of relay catching on lip of molded epoxy coil. The inspector verified replacement of the XKPM-10 magnet kit and a new relay coi In addition, the licensee has re-viced the Corrective Maintenance ESAS troubleshooting procedure to include a sign-off step requiring the checking of ESAS actuation signal indication prior to tripping or removing a channel from servic This item is close .3 (Closed) LER 84-LO-06 and 84-06-03 pertaining to the Second Level Undervoltage Relays in the 4160V E.S. buses ID and IE which continue to drift out of Technical Specification (T.S.) tolerance even though the surveillance frequency has been % creased from refueling interval to six months to quarterly. The supplier indicated these relays are used in an improper application and they cannot certify that the ITE-27H relays are capable of meeting tne specified tolerances. The inspector verified replacement of the ITE-27H relay with an ITE-27N relay that is certified to meet the tolerance requirement of the Technical Specifications 3.5. Calibration was in accordance with SP-1302.5-31A Surveillance Procedure for 4160V D and E Degraded Grid Undervoltage Relay System Calibratio This item is close .4 (Closed) 84-BU-02 pertaining to General Electric type HFA relays in class 1E safety.related applications. The licensee's response (memo No. 5211-84-2166 dated July 13,1984) to the NRC indicates the

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General Electric HFA relay is not used in any safety related applica-tions at TMI-1. However, the bulletin also asks that "the general concerns expressed" for HFA relays on "end cf life" condition for continuously energized AC coils be reviewed for applicability. The licensee's preventative maintenance program for TMI-1 includes the trending of failures such that when a failure rate reaches a pre-determined threshold an engineering evaluation is requeste This practice aids in detecting the end of life condition as well as other failure mechanism This item is close *

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2.5 (Closed) Unresolved Item 85-08-02 pertaining to licensee resolution of MNCR-241-84 and MNCR-009-85 which addresses inadequacies in the Environmental Qualification (EQ) of cables manufactured by Boston Insulated Wire and Cable (BIW) Company. The inspector reviewed the above MNCR's in which the licensee has determined that the BIW cable does not fall under the EQ rule 10 CFR 50.49 as follows:

1) BIW Cable used in Auxiliary Building Fire Detection Modification is not required for safe shutdown in the event of a LOCA/MSL ) BIW Cable used in the Safety Parameter Display System is in the non-IE portion of the system and is not required for safe shut-down in the event of a LOCA/MSL ) Generic use of BIW Cable for systems and components that are not required for safe shutdown in the event of a LOCA or MSLB/FWLB do not require environmental qualification to 10 CFR 50.4 ) 10 CFR 50.49 item F(4) allows qualification of cable by analysis using partial test data for installed cable [Use-as-is based on revision 1 of EQ file EQ-T1-101 (BIW) cable qualified to 00R guidelines.]

5) Memo No. EP&I/84/1829 (E. T. Banua to J. R. Thorpe) dated October 24, 1984 provides the justification for BIW cables with ethylene propylene rubber (EPR) and cross-linked polyethylene (XLPE) insulation to be used under similar circumstances at Oyster Creek pending completion of the required qualification documentation to comply with the 10 CFR 50.49 rul The inspector determined the applicability of MNCR-241-84 for in-stalled BIW cable at TMI-1 to be adequate. This item is close The applicability of BIW cable for future installations as noted in MNCR-009-85 is to remain open pending NRC review of the environmental qualification test data for BIW cable. This item will be listed as unresolved item No. 289/85-15-0 .6 (Closed) Licensee Event Report 83-046 -A nuclear safety related cable for the make-up pump lube oil pressure trip component was found to be incorrectly routed. The present green marked cable was routed in a red channel tray. The cables were originally installed as non-safety circuits and were not upgraded when the circuit was modifie A modification package was prepared to re-route the circuits for the MU-PIA, B and C pumps. This work has been completed (Package N ). In addition to the above, Package No. 830576, which re-viewed-the upgraded systems and components to safety grade to assure that cables associated with the upgrading were properly routed and classified was also complete ,.

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Of.the approximately 1100 tasks involved in this effort, the inspector. randomly selected 35' tasks. In all cases, of the 35 task

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-rected and closed by the license This item is~ close .7 (Closed) Unresolved Item 84-28-01 Equipment qualification files were of normal _ office type and fire protection and access control were-not being complied wit General Public Utility (GPU) Nuclear corporate policy and procedure manual 1000-ADM-731.701, Revision 0-00, dated July 1, 1984 established-a duplicate equipment qualification file at the site to be in ac-cordance with procedure 5000-ADM-7206.01 (TAP-006)

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.The inspector reviewed the site equipment qualification filo system and found it to be in accordance with the licensee's above referenced procedures. The inspector selected file No. EQ-T1-121 titled,

" General Electric Model 5K37JG403 Pump Motor" from the system for review. 'The system designated as-EQ-T1-121 was in.a locked fire proof cabinet and it was'in a limited access syste The inspector did not determine if the data that was part of the package was complete since there was no inventory list sent to the field at_this time. =The data package verification system is-being reviewed by the license This item is close .8 (Closed) Unresolved Items 84-28-02 The quality assurance equipment-files had deficiencies _in identification of what constitutes a data packag GPU Nuclear memorandum dated June 29, 1984_(E and D/TMI/0C-1790)

provides guidance and references procedure 1000-ADM-731.701 which identified the equipment qualification ~ file categorie A review' of four random selected equipment qualification files, from the site data storage area, verified that they were in accordance with the requirements of procedure 1000-ADM-731.70 This item is close .9 (Closed) Unresolved Item 84-28-03 Quality Assurance audits of the equipment qualification records had audit findings open since 198 The licensee's audit of April 15, 1985 identified the responsible L person for answering the due date and the status of the listed b

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finding. A copy of the finding from the corporate audit function is sent to the field. The corporate office tracking system maintains the historical status of the finding until the item is resolve The present method of tracking identified audit findings should re-solve the NRC unresolved item of audit findings not answered in a timely manner. Of the 11 findings identified in the August 31, 1981 audit all have been closed with the exception of finding No. 6A and 10. These two items are in the process of being signed for closur This item is close .10 (Closed) Unresolved Item-83-14-03 pertaining to the Sub-Cooling Margin Instrument Error Analysis requiring verification that the calibration procedure is consistent with the error analysis and assure applicability of the error analysis to presently configured syste The Tsat Margin Monitoring system is a redundant system consisting of two loops. Each loop provides a display of the margin between actual reactor coolant system temperature and the saturation temperature based upon the existing pressure of the reactor system. Components that comprise the Tsat system consist of RTD's Nos. TE-958 and TE-960, pressure Transmitter Nos. PT-963 & PT-949, Signal Condition Module and Digital Indicator Nos. TI-977 and TI-97 Inspector close out is based on review of Unit 1 Surveillance Procedure No. 1302-6.6 for Saturation Ma.rgin channel calibration and Procedure No. 1303-11.52 for checking the operation of the saturation margin monitor and its applicability to presently configured syste Supporting documentation included in this review consisted of Sub-Cooling margin error analysis (licensee memo No. 5211-84-2291) and revised calculations for determining saturation margin error (licensee memo No. 5211-85-2054). Acceptance of the saturation margin monitors is based on satisfying data sheet acceptance criteria of Procedure No. 1303-11.5 The inspector reviewed the test saturation margin monitor data sheets for January 1985 and March 1985 verifying acceptability of saturation margin channels A and B test alarm verificatio Five primary pressure inputs from 125 psig to 2500 psig and current inputs from 4-20-ma DC with alarm actuation at 25"F 1 F and clearing of alarm at 30 F 1*F were' considered for the verificatio Associated with the above, the staff (NRR) has reviewed the final error analysis (dated April 10,1985) submitted by the license This analysis covered the manual (steam table) determination of saturation margin based on pressure and incore thermocouple instru-mentation used below 200 psi Values calculated were based on an analysis which is acceptable to the staff. They accurately represent

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the instrumentation uncertainties associated with the subcooling margin monitor and the use of incore thermocouples to determine the

.subcooling and are therefore acceptable for the intended us (Verification to be done by Senior Resident Inspector.)

This item is close .0 Installation Verification of SER Small Break LOCA Equipment 3.1 The inspector reviewed the following items for compliance with the licensee's commitments stated in the Safety Evaluation Report (SER)

dated March 20, 1985 discussing environmental qualification of TMI-1 electrical equipmen .

3.1.1 Rosemount Transmitters, Model 1153B, Plant ID Numbers MU-23 DPT1, 2, 3, 4 and MU-42-DPT, DH-1, DPT 1 and 2 and MU-14-L The inspector reviewed the work package (No. WA #A25A-30468)

which describes the task to be performed and applicable docu-mentation that is required to be performed. The following documentation which was a part of the work package was reviewed by the inspecto Modification Control Group (MCG) verified the package boundaries,

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Quality Control Incomplete Work List,

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Maintenance and Construction (M&C) Transmittal Sheet,

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TMI-1 M&C Job Order Form,

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TMI-1 Reference Documents Form,

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Sequential Performance Work Steps and Hold Point Form,

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Field Questionnaire / Change Request Change Notice Form,

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Sequential Performance Work Steps and Hold Point Form,

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Field Questionnaire / Change Request Change Notice / Design Change Notice Form,

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Calculations for the static pressure values of the Rosemount Transmitter,

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Installation specification for environmentally qualified decay heat and HPI Flow transmitters (No. T1-IS-412468-001),

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Model 1153B Rosemount Installation Manual, WA-ADL-61- r

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3.1. Equipment Installation Verification The inspector verified that the Rosemount 1153 8 trans-mitters were installed as described in the work package N A25A-30468. The quality control inspection sheet indicated that all open items against the installations have been accepte No violations were identifie .1.2 Weed RTD's Replacing'Rosemount 1390 RTDs The inspector reviewed work package (No. A25E-30460) to assure that the replaced Weed RTD's were installed and that they were in accordance with the following documentation:

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Quality Control Incomplete Work List,

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M & C Transmittal Sheet,

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TMI M&C Job Order Form and Sequential Performance Work Steps Form,

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Document Release Form,

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Construction Release Checklist Form,

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GPU Installation Specification For EQ Penetration RTD's (TE-952A, 953B, 954A and 955 A) No. TI-IS-412468-004, and

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Quality Assurance Review Summary Form 3.1. Equipment Installation Verification The inspector verified that the four Weed RTD's (Nos.

i- TE 952A, 953B, 954A and 955A) replaced the Rosemount 139 RTO's. The inspector also verified that the following RTD-data was within specification tolerance values for:

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RTO Calibration Data Sheets for Temperature reading between 60 F-555 F,

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Instrumentation Loop Test Data, and

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Instrumentation Calibration Data Sheets No violations were identified.

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,3.1.3 -ASCO Pressure Switches Plant ID Numbers PS-479A, B and C The inspector reviewed the work package (A25D-30468) to assure that.the ASCO~ pressure switches were installed on tne make-up (pump auxiliary lube oil system and the.insta11ations'were in accordance with the following documentation

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M&C Form,

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Quality Control Work List Form,

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TMI-1 M&C Job Order and Sequential Performance Form,

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GPU' Document Release Form,

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Installation Specification For EQ Make-Up Pump-Auxiliary Lub 011 Pumps Pressure Switches, No. TI-IS-412468-003,

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TMI-1 Tie In-Document,

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QC Document Review Form,

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GPU Field Questionnaire / Change Request Change Notice / Design Change Notice, and

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Instrumentation Summary Sheet.

[ 13.1. Equipment Installation Verification The inspector verified that the three, ASCO Pressure Switches l PS-479A, B and C, were installed and~ tested. 'During the

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'being teste No violations were identifie .1.4 Transzorb Diode Installations The inspector reviewed the installation data associated with the Transzorb diode installation. This installation was done in two-t different packages. The' installation associated with the valves FW-V-168 and 17B were considered a modification package, since cables also were specified. This was performed with work package No. A27B-54016. -The direct replacement of "In-Kind" parts was performed on Job Tickets Nos. G238 and G240 fe, component ID Nos. 0018 and 000 o

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The data package for the modification No. A278-54016 is simila to the' documents listed in paragraph 3.1.2 of this report with the exception of the GPU RTD installation specification. The installation of the Job ticket installation had no quality in-spection hold point .No violations were identifie .1. Equipment Installation Verification The. inspector verified that the diodes and the cable splices in the XCC and XCL cabinets and the diodes in FW-V-178 and 17C boxes were installed as per the work packages and the drawing No violations were identifie .1.5 Limiterque Motorized Valve Actuators DHV -4A and The uninsulated motor leads on the DHV-4A were corrected by -

using qualified Ray-Chem splicing material per procedure 1420-Y-24 and terminated per procedure 1420-Y-23. Since the work was completed the inspector verified that this hold point was verified. A data review by the inspector indicated that quality control did identify this point and it was inspecte The DHV-4B did not require the motor insulation to be repaired since no damage was identified, however, the existing terminal block was manufactured by the Squ're D Company and this is not on the licensee's qualified parts list. A qualified Buchanan terminal block taken from SMB-3, SSN 476-588-5500-01, replaced the Square D part. The qualified Buchanan block was installed and verified by the quality control inspecto No violations were identifie . Limitorque Motor Replacement - CAV-3 The motor in the Limitorque valve actuator CAV-3 was replaced on Job Ticket CE654. Quality control inspection witnessed the installation of the motor leads splicing on February 15, 198 The inspector verified installation records, calibration and megger data and determined that the results were in accordance with the vendor and procedure requirement No violations were identified.

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3.1.7 Housekeeping During the inspection of the Transzorb Diode modification, Job Tickets MU-V-3,18 and IC-V-3 and work package A278-54016, the inspector determined that the work areas and the equipment were not be'ng maintained as specified in Unit No.1 Administrative Procedure 1020, " Cleanliness Requirements."

In the relay room, elevation 338 foot, the XCC and XCL cabinets-were clean inside but the tops of the electronic cabinets had paper, rubber gloves, dirt, and what appeared to be fire insu-lation materia During inspection of the MU-V-3, 18 and IC-V-3 part replacement the inspector identified dirt, cable tie-wraps, gasket material in the enclosures while the gasket material on the enclosure cover was broken, split and dried out. The conditions described above were corrected by the licensee during this inspection perio The Quality Assurance Modifications / Operations / Quality Control Plant Inspection-Report Form dated March 16, 1985 identified similar type problems. The licensee has a program that is re-viewing the status of maintenance and cleanliness of plant equipment, but was not completed during this inspection perio This item is considered unresolved pending NRC review and evaluation of the licensee's action and the results of their program (289/85-15-02).

4.0 Review of 10 CFR 50.49 Modification Documentation The inspector reviewed the Target Rock Solenoid Valve Modification Package No. EQ-TI-135 to determine current status relating to completeness, legi-bility, retrievability and approval by cognizant authorized personne In reviewing the above documents, the inspector noted that page 2 of 9 (reference No.135-01) and all four pages of reference No.135-05 were not legibl Reference 135-04 on valve No. 80Z-14-008 qualifies valve life for 2.11 years at 215*F, referencing support documentation No. EP&I/84/2065 which was not included in the documentation package. In addition, there were a number of tables and charts at the beginning of the package which contained uninitialed changes or date of chang The licensee was unable to explain the number of deficiencies identified, stating they were just starting to collect the documentation packages and had not established acceptance criteri .-

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.This item is unresolved pending NRC review of licensee action to assure complete, legible documentation (289/85-15-03).

5.0 Unresolved Items Unresolved items are matters about which more information is needed to determine whether it is acceptable or a violatior.. Unresolved items are discussed in paragraphs 2.5, 3.1.7 and .0 Exit Meeting The inspector met with licensee and construction representatives (denoted in Details, Paragraph 1.0) at the conclusion of the inspection on April 19, 1985 at the construction sit The inspector summarized the scope of the inspection and the inspection findings. At no time during this inspection was written material given to the licensee or his representatives.