IR 05000289/1985026

Safety Insp Rept 50-289/85-26 on 851026-1112.No Violation Noted.Major Areas Inspected:Letdown Sys Operation,Nuclear Svc Closed Cooling Sys Reactor Bldg Penetration Design Adequacy & Turbine Bldg Fire Loading

ML20138J029
Person / Time
Site:	Crane
Issue date:	12/12/1985
From:	Conte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20138H992	List: IR 05000289/1985026 ML20138H989 ML20138J029
References
50-289-85-26, NUDOCS 8512170415
Preceding documents:	ML20154A646 (14 January 1986)
Download: ML20138J029 (36)

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U.S. NUCLEAR REGULATORY COMMISSION i REGION I Report No.' 50-289/85-26 Docket N License N DPR-50 Priority -- Category C Licensee: GPU Nuclear Corporation Post Office Box 480 Middletown, Pennsylvania 17057 Facility At: Three Mile Island Nuclear Station, Unit 1 L

Inspection At: Middletown, Pennsylvania

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Inspection Conducted: October 25-November 12, 1985

~ Inspectors: - D. Falconer Jr. , Lead Reactor Engineer, Region II b' ' ~ ~

D'.' H'averkamp, ' Technical Assistant for"7MI-1 Restart, I

Region I D. Johnson, Reactor Engineer, Region I i

L. Reidinger, Instructor,. Reactor Training Center T. 'Stetka, Senior Resident Inspector (Crystal River),

Region II R. Urban, Reactor Engineer, Region I D. Vito, Senior Emergency Specialist, Region I J. White, Senior Radiation. Specialist, Region I F. Young, Resident Inspector (TMI-1), Region I

' Contractor Personnel: W. Apley, Associate Manager, Energy-Systems, Battelle Pacific Northwest Laboratories (PNL)

T. Morgan, Operator Examiner, EG&G Idaho, In Approved By:

R. Conte, TMI-1 Restart Manager

/2!// I-Date-TMI-1 Restart Staff Division of Reactor Projects l

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8512170415.851212 PDR ADOCK 05000289-G PEH4

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Inspection' Summary:

The TMI-1 Restart Staff conducted routine and special (NRC shift coverage)

safety inspections. (501 hours0.0058 days <br />0.139 hours <br />8.28373e-4 weeks <br />1.906305e-4 months <br />) of power operation focusing on operator and man-agement perfo.rmanc Specifically, items' reviewed in the overall facility op- -

eration. area were: letdown system operation, nuclear service closed cooling system reactor building penetration design adequacy, turbiac building fire loading, and procedure implementation issues noted during shift inspector re-views. Other review items included: makeup system leak, implementation of administrative controls in the area of plant staff working hours, diesel gener-ator maintenance an'd operability, and safety grade emergency feedwater inplant revie '

Inspection Results:

Facility personnel continued to conduct themselves in a professional manne ~

Licensee management and quality assu_rance department personnel continued their attentiveness and involvement in daily' activitie The training department is an apparent strength contributing to the overall positive performance of per-sonnel. In addition to personnel. performance, the material condition of the plant was~also conducive to safe operation, including avoidance of plant trips and challenges to safety-related systems. The radiological controls department continued-to exhibit itself as a strength ir. the licensee's organizatio Some communications lapses occurred but are considered mino In general, facility procedures were properly. implemented. However, certain

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problems in adhering to procedural steps (some of which were compounded b lack of clarity) were indicative of a potentially adverse tren Increased licensee management attention to this area may be warranted, and the TMI-1 Re-start Staff will continue to review this matte Personnel involved locally with a leak in a makeup pump cubicle performed poor-ly.in using a standing radiation work permit for draining a radioactive system and'in not isolating the leak before evacuating the cubicle. Control room per-sonnel were responsive to the event and licensee post review critique and cor-rective actions were appropriate for the circumstance The following items require further review and will, therefore, be addressed in subsequent inspections: (1) design adequacy of the nuclear services closed cooling water system reactor building penetration, and (2) maintenance and post-maintenance test data for the recent diesel generator outage The licensee needs to provide some additional information for the staff regard-ing the safety grade design considerations of the emergency feedwater syste '

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DETAILS Introduction and Overview 1.1 General Throughout this inspection period, the TMI-1 Restart Staff provided onshift inspection coverage 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> a day to assess restart operat-ing activities. This coverage was consistent with the reduced level of testing activity and steady-state facility operation at the 48%

power plateau. The staff's observation of plant activities was main-tained by NRC personnel from Region II and the Reactor Training Center and by reactor operator examiners from Battelle Pacific North-west Laboratories and EG&G Idaho, Inc., both NRC contractors. Also, Region I inspectors continued periodic coverage of testing activi-ties. Additional Region I personnel were on site during portions of the period-to augment the resident inspection staf ' Facility Restart Operations During the period of October 25-November 12, 1985, the significant TMI-I restart operational milestones included: (1) continued main turbine generator operation at the 48% plateau, and (2) one minor power level change for integrated control system tuning. The chrono-logical- summary of plant operations during the period is presented belo Date Time Operational Highlight-or Milestone 10/25/85 7:00 Reactor at 48% of rated power, reactor coolant average temperature at 578 de-grees F and pressure at 2150 psig 11:15 Main turbine transferred to manual due to electro-hydraulic control signal cycling;. reactor power reduced to 45%

11:55 Returned reactor to 48% power 11/8/85 1:00 Reduced power to 40% at 2% per minute in accordance with test procedure TP 800/1 1:20 Returned reactor power to 48% at 2% per minute in accordance with TP 800/1 11/12/85 7:00 At the end of this inspection period the reactor was at 48% of rated power, reactor coolant average temperature was 579 degrees F, and pressure was 2155 psig

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1.3 Operational Events Several events occurred during this inspection period that were con-sidered either operationally significant or were matters of special interest to the TMI-1 Restart Staff. These events are discussed

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belo On October 25, 1985, electricians were measuring decay heat pump vibration signals- from a cabinet in the relay room. The workers used a power source on the integrated control system (ICS) panel to pro-vide power to the test equipment. This caused an electrical inter-

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ference signal with the main turbine electro-hydraulic control (EHC)

system. The EHC system tripped to manual and the system closed the turbine stop/ control valves. The plant responded as expected. Tur-bine header pressure increased to 1035 psig, and two atmospheric dump valves, two turbine bypass valves, and a main steam safety valve were actuated. The operators quickly took manual control of a mein feed-

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water pump and the turbine generator and stabilized the plant transi-ent. Within an hour, the ICS was placed into automatic control and the plant was returned to steady-state conditions at 48% powe On October 29, 1985, the TMI-1 Restart Staff was informed that a leak

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of 150 gallons of primary water from the makeup and purification sys-tem occurred between 4:20 and 4:30 p.m. on October 28, 1985. At the time, licensee personnel were conducting corrective maintenance on a minor leak from one of the' three n'akeup pumps. The pump was isolated by closing valves on each side to permit depressurization and drain-i.ng of the pump. Since one of the isolation valves leaked, draining of the pump continued for an extended period of time. A local radia-tYon monitor alarmed causing an evacuation of personnel from the pump

cubicle. Escaping radioactive noble gases caused ventilation process monitors to respond but not alar Licensee personnel reentered the punp cubicle and secured the leak. The licensee estimated that ap-proximately 0.7 Ci of noble gases (primarily Xe-133) were released to the environment and dose calculations indicated that the release was a small. fraction of regulatory limits. The licensee conducted a cri-tique of the' event (see paragraphs 2.1 and 4).

On November 2, 1985, at 9:30 a.m., the licensee attempted to repair a small water-leak on a flange in the secondary plant moisture separa-tor drain system which is located in the turbine building. Because the section of piping was not effectively isolated, a steam leak oc-curred at the flange as the flange bolts were loosened. The leak was fed by relatively hot water from the steam and feedwater syste Some of the workers involved in the repair received superficial burns that did not require offsite medical attention. The steam: leak last-ed approximately 20 minutes. Although a minor perturbation was no-ticed in feedwater flow, the plant remained at steady-state 48% power condition .

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On November 4, 1985, emergency diesel generator IA was, removed from service, as permitted by the plant's technical specifications, for annual preventive maintenance and inspections. The diesel was re-turned to service on November 8, 1985, and a 24-hour operational test with the diesel generator loaded to 3000 KW was completed satisfacto-rily as well as other required post-maintenance surveillance testin After that diesel was officially declared operable, the redundant emergency diesel generator 1B was removed from service on November 11, 1985, for similar annual maintenance and testin 'On November 5, 1985, a 120V ac bus was deenergized by a licensee technician who opened a supply breaker in response to arcing and sparking at an adjacent breaker. Technicians were performing breaker preventive maintenance on an engineered safeguards bus at the tim 'Although no significant loads were lost as a result of the bus being deenergized, the electrical incident was apparently due to technician error. The deenergized bus was an alternate power source for the integrated control system .(ICS)/non-nuclear instrumentation (NNI)

bu The ICS and NNI remained energized. The reactor protection and engineered safeguards actuation systems were unaffected because they were powered from separate vital buses. The licensee has taken dis-ciplinary action against the technician On November 5, 1985, the licensee removed one of two letdown coalers from service because of an indicated leakage at the rate of 1.3 ,

liters / day. The leakage of reactor coolant system water was into the intermediate closed cycle cooling water system, a non-safety syste The leakage was first detected on October 24, 1985, by'racioactive

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noble gas sampling and was trended on a daily basis. Although the cooler is still considered to be operable by the licensee, it is not in service. The licensee has a spare letdown cooler available on site if neede .4 Summary This inspection included restart testing activities at the 48% power plateau. During this period there were no interruptions of the re-start testing program due to equipment problems or other reason The' shift inspectors referred only implementation matters or status questions to shift supervisory personnel and referred programmatic matters (event followup, design or procedure adequacy problems) to resident and region-based NIC personne Resident and region-based personnel interfaced with licensee support groups in followup to shift inspector referrals /cor.cerns. The staff's observations and findings regarding plant operation and testing and licensee response to operational events is discussed in the report sections that follow.

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6 Shift Inspection Activities 2.1 Scope of Review and Observations

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During the period of Octobr~ 25-November 12, 1985, the TMI-1 Restart Staff continued its augmented shift-inspection coverage. The NRC shift inspectors assessed the adequacy and effectiveness of operating personnel performance based on the inspectors' observations of oper-ating and startup activities to determine that:

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operators are attentive and responsive to plant parameters and conditions;

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. plant evolutions and testing are planned and properly authorized;

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procedures are used and followed as required by plant policy;

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equipment status changes are appropriately documented and commu-nicated to appropriate shift personnel;

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the operating conditions of plant equipment are effectively mon-i.tored and appropriate corrective action is initiated when required;

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backup instrumentation, measurements, and readings are used as 3 appropriate when normal instrumentation is found to be defective r or out of tolerance;

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logkeeping is timely, accurate, and adequately reflects plant activities.and status;

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operators follow good operating practices in conducting plant

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operator actions are consistent with performance-oriented trainin ,

The shift inspectors' observations included, but were not limited to, those reactor plant operation and testing activities, periodic sur-veillance activities, and preventive and corrective maintenance ac-tivities listed below.

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Reactor Plant Operation and Testing Activities

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routine con. trol room operations including annunciator alarm re-sponse and control room logkeeping

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operating and emergency procedures discussions with shift. super-visors,. shift foremen, control room operators and shift techni-cal advisors

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periodic inspection observation tours of areas outside the con-trol room, including diesel generator rooms, emergency feedwater rooms, control building, turbine building, auxiliary building, intermediate building, electrical switchgear rooms, and outside buildings and yard areas

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hydrogen addition'to core flood tank 18 to increase tank pressure

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operating crew response to main turbine electro-hydraulic con-trol system signal causing unexpected turbine control valves closure

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routine-operations and maintenance planning briefings between operations plant manager and shift supervisors

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operator' response to incorrect securing of reactor coolant bleed and feed operations when MU-V-8 was not placed in.the proper

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periodic blowdowns of instrument air compressor aftercooler wa-ter trap ,

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fire fighting training drill in burn building for Londonderry Township' Fire Company-

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shift crew respcnse to kinked fire hose found during periodic surveillance

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shift crew training session during backshift

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changeover and recharge of powdex vessel I licensee personnel critique regarding leakage and spill from makeup' pump MU-P-1A that' occurred on October 28, 1985

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shift crew briefings regarding plant incident reports 1-85-13,

"PORV Setpoint Check," and 1-85-14, " Leakage and Spill from Makeup Pump" I --

shift crew actions in response to inoperable reactor building

fire system annunciator

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radiation work permit posting practices

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operating crew response to inadvertent draining of reference leg to differential flow transmitter DPT-922 for safety valves dis-charge piping

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operator response to chlorine leakage in circulating water pump house

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liquid release permit L8511092, documentation completion and initiation of release from waste evaporator condensate storage tank 1 securing of waste gas release from waste gas decay tank 1A and-release permit G8511075 documentation completion

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operating crew response to steam leak from moisture separator drain pump 1A discharge flow control valve MO-V-1A, which re-suited during' loosening of flange bolts in valve

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waste gas release permit G8511076 documentation completion and initiation of release from waste gas decay tank 18

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operating crew response to loss of regulating bus TRA caused by '

incorrect power supply breaker operation by electricians after arcing occurred in emergency safeguards bus IA motor control center unit IDL

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transfer of main feed pump 1B from manual to automatic mode of operation and then back to manual when pump appeared to start hunting again

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operating crew removal of the annunt.ator card for heating and ventilation panel' alarm B-4-5, " Air Supply Tunnel Combustible ~

Vapor"

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bypassing of reactor protection system channel 1B due to appar-ent out-of-specification variable pressure / temperature module

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operating crew response to moisture separator high level alarm and low level alarm conditions

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radiological controls personnel response to posted radiation work permit No. 031257 that shift inspector found to have ex-pired on previous day (November 6, 1985)

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operator performance of valve lineup and switch position chec after maintenance of emergency diesel generator 1A

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plant-maneuver from 48% of rated power to 40% and back to 48%

for integrated control system tuning

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shift crew fire brigade meeting conducted by shift maintenance foreman p'rior to normal shift briefing periodic Surveillance and Maintenance Testing

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. emergency safeguards channels surveillance testing associated with emergency diesel generator IB

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reactor protection system / nuclear instrumentation channel 1A calibration per surveillance procedure 1303- reactor trip breaker periodic testing

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reactor building spray pump 1A surveillance testing

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hydrogen recombiner IB surveillance operational testing

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emergency diesel generator IA protective relays calibration per surveillance procedure 1302-5.30

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emergency diesel generator IA voltmeter calibration per surveil-

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control rod movement surveillance per SP 1303- emergency diesel generator IA post-maintenance surveillance testing per surveillance procedures 1301-8.2 and 1303-4.16 and operating procedure 1107-3

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setting of emergency diesel generator'1A governor high limit per procedure 1420-EG

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post-maintenance surveillance testing of repaired square root extractor for reactor protection system loop 1B flow

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surveillance testing of ' reactor building isolation channel 3 per procedure 1303-4.13

-- _ reactor. building local leakage measurements-for access hatch door seals per surveillance procedure 1303-11.25

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Preventive and Corrective Maintenance Activities

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~ tightening of building spray pump isolation valve BS-V-1A pack-ing to stop leakage of 12 drops / minute

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troubleshooting on fire panel in control tower being performed by instrument and controls technicians

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emergency diesel generator 1A annual ~ preventive maintenance and inspection per procedure 1301- troubleshooting of ground on station battery 1A being performed by electricians

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repairs to leaking heater drain pump flange

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phase bus heating test to determine ~ temperature rise with fan -)

secured in preparation for replacement of_a fan bearing

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repairs to moisture separator drain tank dump valve ~ controller LC-77A

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troubleshooting and repair of "B" loop square root extractor for reactor coolant system flow

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spray welding of phase bus cooling fan shaft

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pre-maintenance tagging activities for. emergency diesel genera-tor 18 annual inspection, including racking out of generator output breaker

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electrical checks of thermal breaker trip setpoint for the prelube oil pump breaker in panel IB per preventive maintenance procedure E-62

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performance of various maintenance activities related to annual inspection of emergency diesel generator IB In addition, shift inspectors conducted or contributed to the follow-ing special reviews of facility design and operational matters or of the licensee's administrative controls program control room panel indicators operational review, including use of temporary labelling and instrument accessibility

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containment-isolation. valves installation review for nuclear service closed cooling water to reactor building cooling unit fan motors

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surveillance. procedure lineup requirements for containment pres-sure instruments test "T" connections

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reactor building pressura instruments for emergency safeguards-actuation channels installation review

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decay heat closed cooling system surge tank level instrumenta-tion calibration review

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followup review to leakage and spill from makeup pump MU-P-1A that occurred on afternoon of October 28, 1985

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followup review of main turbine control valve closure including review of plant incident report 1-85-14

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interviews with selected licensed-operators regarding restart qualification training evolutions

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calibration procedures and data review for computer po:nts used to perform the reactor coolant system leak rate calculations

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administrative controls for out-of-service equipment

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printer /CRT display of computer group 55 data (reactor power, imbalance, quadrant power tilt, rod index)

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locked valve and component listing and sampling ch ck of locked valves and breakers for conformance with administrative proce-dure AP .1011, " Locked Valve and Key Control"

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borated water concentration in boric acid mix tank conformance with operating procedure 1140-47B:

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methods for calculating sodium hydroxide tank and borated water storage tank levels

-- -hand-and-foo't monitor calibration practices per procedure 9000-PMI-4221.16 2.2 Assessments of Shift Inspectors 2.2.1- General'

The shift inspectors assured that any potentially adverse safety concern or regulatory finding was identified prompt-ly to both the. licensee's shift supervisor and the TMI-1 Restart Manager. Those items requiring additional staff review or followup are described in paragraph 3 of this -

report. Also, at the end of their assigned period of shift inspection activities, the inspectors provided their gener-al assessment of facility operational readiness and person-nel. performance. These general assessments included, as t-

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applicable, each inspector's overall views related to oper-

=ating staff performance, fire protection, maintenance, sur-veillance, radiological controls, training, emergency planning, and physical security. The inspectors' assess-ments are presented belo . Operating Staff Performance Shift inspectors continued to provide many positive com-

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ments on.the knowledge level and overall quality of perfor-mance of-facility operating, maintenance and technical staff personnel similar to that described'in previous in-spection reports issued since criticality. -This period

. reflected _the first opportunity for NRC staff to observe personnel during normal steady-state power evolution It was during this period that shift inspectors observed a relatively large sample of mechanical, instrument and con-trols, and electrical maintenance and testing similar to that which would be conducted during.100% power operation The focus in this period was plant operations, not restart testing. Overall, personnel interfaced well with one an-other in support of the operations department. However, some indications of performance problems were reveale As an example, shift inspectors intensely reviewed proce-

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dure implementation by the various departments within the TMI-1 division. . They observed a number of instances where procedures could have been better written or where certain individual steps were not ~ properly followed. They referred

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.these problems to the region-based staff (see paragraph 3.2.5). In general, procedures were adequate and properly implemente During observations of control room personnel, shift in-spectars, in general, found them to be professional in their approach to shift operations. Communications were handled effectively-and during this time no problem attrib-utable to unclear communications occurred. During a steam leak in the secondary plant on November 3 (see paragraph 1.3), licensee. personnel response was controlled and they remained-calm and rational during the event. The leak was identified by an auxiliary operator and maintenance person-nel. The shift foreman was dispatched to the scene and.the leak was isolated quickly. Subsequently, the auxiliary operators were called to the control room and the opera-tions manager outlined for the crew how the system would be returned to normal. They then followed a step-by-step pro-cedure in returning the system to normal statu .

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Similar comments can be made about the loss of the TRA bus on November 5, 198 The licensee will be issuing plant incident reports on both event The adequacy of the licensee's review of this event is unresolved pending com-pletion of~ licensee action as noted above and subsequent TMI-1 Restart Staff- review (289/85-26-01).

Shift foremen were using the control room operator's (CRO)

log to complete the right side of their log for event / evolution chronology before shift turnover. It ap-pears that they rely on the CR0 log for detailed secretar-fal type recording of routine evolutions and events. Non-routine events are recorded on the left-hand side of the log and they appear to be original entries. These entries encompassed technical specifications action statements, reportable events or items of potential public interest, and major events. The inspector noted that the copying of the CR0 log in the shift foreman's log diminished the use-fulness of the shift foreman's log for independent event analysi Overall, operators.and technicians continued to perform in a competent and professional manne .2.3 ~ Training In general, shift inspector observations continued to sug-gest that the training department provided sufficient knowledge and assured demonstrated skills to support the performance of activities in a' safe and professional man-

.ner. However, the procedure implementation problems de-scribed in paragraph 3.2.5 suggest additional management attention to personnel making changes to procedures for improvemen A primary focus during this inspection period was the im-plementation of the licensee's restart qualification pro-gram (NRC Inspection. Items 289/81-33-04 and 289/84-19-01).

The TMI-1 Restart Staff initial review of the program con-sisted of reviewing the qualification cards. The cards were set up according to operating crews. The system was established so that most of the operating crews observed or performed most of the items listed. This meant that no individual qualification card was required, and, as stated in a licensee inter-office memorandum, every person was not required to have been involved in every evolutio It ap-peared as though the basic purpose of the cards was to en-sure that at least a specified level of operating experi-ence existed prior to the plant operating and returning to

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power after the 100% trip test. Licensee management con-firmed that the qualification cards were not training docu-ments, but.they were a means to record crew experiences versus simulations to identify any significant shortcomings in experience level at the end of the power escalation progra Interviews with shift personnel revealed a general at'titude that the restart qualification card program was not effec-tive in achieving a training purpose. One contributing factor was that most of the items were either simulated or walked through and, therefore, did not provide the operat-ing experience desired. Another reason is that the majori-ty of the-items were completed in 1983, two years prior to the plant startup, and no program existed for followup re-view to assure retention of the information. Licensee man-agement indicated its intentions to update the qualifica-tion card to reflect recent experience gained during the power escalation program Shift inspectors conducted interviews of four operating crews (A,C,E,F) including a total of eight reactor opera-tors and three senior reactor operators. The questions asked were performance oriented taken from two qualifica-tion card sections, primary and power escalation, since these had the most applicability to present plant configuratio The overall knowledge level;in these areas was considered average or above, as determined by the NRC examiners' ex-pectations. There appears at this point to be no areas of unexpected poor knowledge with respect.to license. examiner standards. The inspectors initially concluded that the qualification card program at this point was of little val-ue in assessing the operators' knowledge level or in mea-suring performance results to date. Two years of additional training provided by the training department prior to startup was the key factor in enhancing operator performanc This area will continue to be routinely re-viewed during the 48% and 75% power plateau .2.4 Startup Testing During the implementation of the residual ICS tuning tests from previous power levels,.the shift inspectors observed good personnel communications and proper implementation of-the applicable test procedures. Licensee personnel demon-strated. good overall control of the evolutions, m

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2. Maintenance Preventive and corrective maintenance continued to be ag-gre'ssively pursued and promptly effected. Overall control of the'"A" diesel generator outage was good (see paragraph 6).

Problems with inexperienced backshift personnel continue to be evident although this has not as yet caused a challenge to a safety-related system or adversely affected safe.oper-

.ation of the facilit c 2. Surveillance Surveillances required by the technical specifications (TS)

were conducted at the specified frequency without excep-tion. This appears to be due to the implementation of-a strong administrative program which assures performance c?

TS surveillances at the specified frequenc The surveillance tests were performed in a slow deliberate manner ensuring that each step was completed prior to pro-ceeding to the next step. During the performance of the

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reactor protection system calibration, a question arose as-to the requirement for shift supervisors' signatures on attached data sheets. After talking to the shift supervi-sor, an operations engineer, and an instrument and controls representative, the shift inspector considered that it ap-peared as though they understood when the signature was required, although the data sheet was-vague in its wording (see paragraph 3.2.5.3).

2.2.7 -Radiological Controls-Radiological controls, including. personnel monitoring and area posting, appeared adequate. The licensee has done a commendable job in reducing contaminated areas. Radiation levels throughout the facility were very low, but-this could be due to the relatively short operating time for the plant since the October startu On November 11, 1985, a problem was noted in that a hand-and-foot monitor was in use and beyond its calibration due date by three days. Radiological controls management acknowle'dged that condition. This finding was contrary to Radiological Controls Procedure 9000-PMI-4221.16, which requires quarterly calibration of the instruments. They-indicated that the instrument became inoperable due to the out-of-calibration period expiring ~at midnight of the due day and that no allowances are made to exceed this dat . - . . -

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'16 The' field operations manager checked with the Radcon in-strument person _nel 'and the computer printout of October 26, 1985, indicated that calibration of this instrument was

~ due. Radcon management attributed the missed calibration to a move.in the facility where radcon instruments were Estored. The manager also stated that this was no excuse

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.nel monitoring station was available at,the Unit 1 Process-ing Center. As a result of the use of the

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out-of-calibration instrument, there was no incident of contaminated personnel leaving-Unit The inspector had no further questions on this' matte Review of applicable radiation work permits (RWPs) on November 1, 1985, revealed that all general RWPs in effect

, .for October.were renewed and properly placed on the bulle-tin board. .On'e minor problem was noted in.that RWP N expired on November 6,1985, but it was still posted on November 7, 1985. Apparently,-no individual used that RWP during its' expired time period. Review of RWP require-ments for'the building spray surveillance test and personnel performing the-test showed-full compliance with the RW During periodic tours, all high radiation area doors were clearly marked and locked. No discrepancies were found.

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2.23 Physical Security Based on routine observations of security systems _ operation and guard performance, no adverse conditions were identified in this are .3 Conclusion Overall, facility personnel continued to conduct themselves in a pro-fessional manner. The shift inspectors attributed the procedural-implerrentation problems to a lack of- attention to detril on the part of plant personnel ~(see paragraph 3.3 for more_information). Opera--

tor response to minor events was conducted in a controlled and calm manner. Overall, licensed operators continued to demonstrate good knowledge of facility-design and of daily. plant statu __The routine training program, in distinction to the restart qualifi-

-cation card program, apparently contributed to the quality of person-nel performance since the plant startu The radiological controls program continued to evidence itself as a-strength in the licensee's organizatio .

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3. Plant Operations 3.1 Scope of Review TMI-1 Restart Staff inspectors periodically inspected the facility to determine the licensee's compliance with the general operating re-quirements of Section 6 of the Technical Specifications (TS) in the following areas:

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review of selected plant parameters for abnormal trends

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plant status from a maintenance / modification viewpoint including plant housekeeping.and fire protection measures

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control of ongoing and special evolutions, including control room personnel awareness of these evolutions

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control of documents including log-keeping practices

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implementation of radiological controls

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implementation of the security plan including access control, boundary integrity, and badging practices

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The inspectors also focused their attention on'the areas listed belo control room operations during regular and backshift hours, in-cluding frequent observation of activities in progress, and periodic reviews of seiected sections of the shift foreman's log and control room operator's log and other. control room daily

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followup items identified by shift inspector activities (se paragraph 2)

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areas outside the control room

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selected licensee planning meetings As a result of this review, the inspectors reviewed specific events in more detail as described in the sections that follo .2 Findings 3. General In general, housekeeping and fire protection measures re-mained consistent with previous high standards in safety related areas. The licensee has done a commendable

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job in ensuring safety-related spaces are well kept and free of litter. The practice of assigning each space to a particular department and a particular person in that de-partment ensures that someone is ultimately responsible for the cleanliness of that space. All anti-C clothing was stored in designated areas in a neat manner. Containers were clearly marked as to the type of trash or clothing that was to be deposited in eac In the turbine and control buildings, the practice of plac-ing absorbent materials under machinery that may have oil leaks ensured that the oil was contained within the bounds of the machinery. Fire loading in the turbine building was addressed (paragraph 3.2.4).

Overall, the material condition of the plant remained quite good. Plant performance continued to be as expected.with only minor safety related equipment problem Management involvement and attentiveness to daily activi-ties continued. The maintenance department's daily plan-ning meetings continued to keep management-abreast of plant problems and to provide overall direction to proceed delib-

.erately and cautiously during steady-state power operation . Letdown System Operations On October 25, 1985, the shift inspector witnessed the con-trol room operators secure portions of the lineup associat-ed with transferring (letting down) water from the reactor coolant system via the letdown system to a reactor coolant bleed tank. While performing the evolution, the shift in-spector noted some confusion between the control room oper-ators on the proper sequence of valve repositionin .

The TMI-1 Restart Staff reviewed and discussed with a se-nior plant engineer the sequence of valve repositioning that should occur during this evolution. This review was performed initially using current plant drawings in order to verify the accuracy of the procedur'e. The inspector then discussed the procedure with the operating crew that had performed the water transfer on October 25, 1985. The control room operator walked.the inspector through the steps that they had performed. From the walkthrough and review of the drawing,.the inspector concluded that the applicable procedu're was correct as written. The problem arose because the two operators involved did not properly communicate their actions to each other.

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In the sequence of valve repositioning, the operators are required to reposition the bleed valve (MU-V-8) from the

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" bleed". position to the "through" position and then isolate the bleed tank to which it is being draine If the isola-

-tion valve associated with the blet tank is shut before MU-V-8 repositions, the letdown sys tm would be pressurized to reactor coolant system pressure and challenge the let-down system relief valve. Control of MU-V-8 is from the

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center console in.the control room while the bleed tank isolation valves are controlled from the liquid waste dis-posal system panel in the back of'the control roo The-operator at the center console requested that a second operator walk over and shut the bleed tank isolation valv The operator at the console noted that pressure in the ~

makeup tank was high in its operating band. He paused for a moment to allow pressure to drop before cycling MU-V-8; however, the operator had already started for the panel at the back of the control room. The shift supervisor who realized that the valves were going to be repositioned in the wrong order, which would cause the letdown system re-lief valve to actuate, took control of the evolution and remedied the situation. As a precautionary measure, the shift supervisor had the control room operators check the indications in the control room to ensure that the relief valve did not lif Discussions with the operators indicated that-the operator at the center console had miscommunicated his directions as to when to shut the bleed' tank isolation valve. Prior to these discussions, the shift supervisor had personally re-viewed the situation with his crew. The inspector noted that the operators on this shift were fully knowledgeable of the interactions of the two systems involve From re-view of the control room records.and discussions with the operators, the inspector concluded that the relief valve in question had 'not lifted and the shift supervisor had main-tained positive control of evolutions occurring in the plan . Nuclear Services Closed Cooling Water Relief Valve Design Adequacy The inspector reviewed the reactor building isolation valve arrangement of the nuclear services closed cooling water system. This review ~was in response to a shift inspector's concern raised during a tour of the intermedi-ate building during'the previous inspection period. The

! arrangement consisted of relief valves (NS-V-36 A, B & C)

between.the reactor building wall and the isolation valv As part of.this review, the following documents were examined.

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GAI Drawing C-302-610, " Nuclear Services Closed Cycle Cooling Water System," Revision 31

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SP 1300-3J, "NSCCW Pump and Valve Functional Test,"

Revision 9, dated July 23, 1985

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TMI-1 FSAR Section 5.3, " Isolation System," dated July 1982

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Operations Plant Manual, Section B-11, " Nuclear Ser-vices Closed Cooling Water," Revision 0

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OP 1104-11, "NSCCW System," Revision 23, dated Septem-ber 26, 1985

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10 CFR 50, Appendix A, Criterion 57, " Closed System Isolation Valves"

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Safety Evaluation by the United States Atomic Energy Commission, dated July 11, 1973 This as-built configuration of the reactor building isola-tion valve arrangement for the NSCCW system is:

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entrance isolation valves NS-V-52 A, B &.C

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reactor building penetration-

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fan motor coolers IA, IB & IC

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reactor building penetration

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relief valves NS-V-36A, B & C

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exit isolation valves NS-V-53 A, B & C The purpose of the NS-V-36 relief valves is to protect the fan motor coolers against. rupture in case an overpressuri-

~zation condition were to occur. The relief valves were set at 175 psi The NSCCW. system pressure is kept above the maximum pres-sure attainable in the reactor building following a LOC If a break were to occur, leakage would be into the reactor building. -However, the NS-V-36 relief valves are located in a position such that an unisolable leak may develop be-tween the reactor building and the intermediate building. This could occur if the NSCCW system isolated

causing the relief valves to lift and, subsequently, not close. When system pressure dropped below reactor building pressure, a line break would open a path outside of containment.

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Criterion 57 of Appendix A, 10 CFR 50 states: "each line

.that penetrates primary reactor containment and is neither part of the reactor coolant pressure boundary nor connected directly to the containment atmosphere shall have at least one containment isolation valve which shall be either auto-matic or locked closed or capable of remote manual isola-tio This valve shall be outside containment and located as close to the containment as practical."

The TMI-1 FSAR, Section 5.1.2 classifies the NSCCW system as a Type III fluid penetratio Therefore, it must have at least.two isolation barriers; the first must be at least one valve, either a check valve or a remotely operated valve located external to the reactor building. The closed loop is considered the second barrier. . Table 5.3-2, "Reac-tor Building Isolation Valve Information," in conjunction with Figure 5.3-1,." Reactor Building Isolation Valve Ar-rangement," depicts a configuration that does not truly

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reflect the as-built condition of the NSCCW syste Licensee representatives stated that the relief valves were located outside primary containment so that water would not be added to containment during a LOCA if the relief valves-were to lift. They also stated that TMI-1 was 60% complete when the FSAR was submitted to the Atomic Energy Commission (AEC). This was~before the present version of the General Design Criteria (GDC) was published in July 1971. The plant was designed and constructed to meet the intent of the original AEC's GDC proposed in July 1967 and other as-pects were reflected in the staff SER for facility opera-tion issued prior to the 1974 criticalit The TMI-1 Restart Staff is questioning the design adequacy of the relief valve configuration present in the NSCCW sys-tem. The implications of having a stuck-open relief valve outside of containment concurrent with a break of the NSCCW piping inside containment.could violate containment integ-rit However, the probability of this occurring appears to be extremely lo Further NRC review of this matter will be necessary to de-termine the design adequacy of the valve configuration and

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to determine if the licensee is meeting GDC 57. The re-sults of this review will be documented in a future inspec-tion report (289/85-26-06).

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3. Turbine Building Housekeeping / Fire Hazard Based on several walkdowns by shift inspectors, the turbine building physical appearance led to the question of whether the turbine building posed a fire hazard and could cause a significant plant transient that would have an adverse ef-fect on' plant safet The inspector performed an indepen-dent walkdown.in the turbine building and developed a list of potential fire hazards. This list was then compared with a list that'is. prepared by licensee fire protection engineers on a weekly basi The inspector did not identi-fy any new findings that had not been identified by the licensee personne Based on discussions with licensee representatives and a review of previous findings, the inspector determined that if a significant fire hazard existed in the plant, immedi-ate corrective actions were taken. The inspector noted-that many of the NRC shift inspectors' observations were

. scheduled'as part of maintenance wor The inspector con-cluded that the licensee was appropriately identifying and correcting potential fire hazards in the entire plan '

Because of the sign'ficant amount of burnable materials in the turbine building, the inspector questioned wnether a fire hazard loading review had been perform'ed for the tur-bine building. The inspector questioned whether the amount of material might exceed the capabilities of the fire sup-pression system in the turbine building. Through a review and discussion of the fire _ hazard analysis performed, licensee representatives demonstrated that the loading did

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not exceed the s/ stem design and that they were tracking the changes in the loading of burnable material in the tur- l bine buildin The inspector concluded that the turbine building condi-tions.did not-create a hazard that would affect plant safe-t However, the inspector noted that the physical appearance of the turbine building was not maintained as well as the rest of the plant. The TMI-1 Restart Staff expects to continue to receive subjective comments about the physical appearance of the turbine building from shift inspector . Procedure Implementation As a result of shift inspector referrals, the TMI-1 Restart t Staff reviewed the below listed findings to get a better understanding of those findings and to assess their overall safety implication *

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3.2.5.1 During liquid releases from the waste evaporator condensate storage tanks on November 1 and 6, 1985, the NRC shift inspector observed that the instrument and con-

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trols technician performed A, B, and C steps of paragraph 1.3 of the applicable operating procedure out of sequenc The operating procedure (0P) was OP 1104-29S, Revision 30, September 5, 1985, " Transfer from'the Waste Evaporator Con-densate Storage Tank," and it referenced surveillance pro-cedure (SP) 1302-3.1, Revision 43, October 1, 1985, "RMS Calibration." Appendix A, paragraph A.9 of that appendix required essentially the same steps as B.1, B.2, and B.3 of OP 1104-29S. Further review by.the TMI-1 Restart Staff revealed that the proper sequence of steps was: calcula-tion of the setpoint for RM-L6 bigh alarm to close the dis-charge isolation valve; setting the calculated setpoint into the instrument RM-L6; and performance of a functional check of the interlock prior. to the discharge. The OP 1104-295 did not reflect that proper sequence but the tech-nician performed the evolution in the appropriate sequence without signoff on SP 1302- The licensee initiated a procedure change request to cor-rect the deficiencies of OP 1104-29S and to correct some other minor discrepancies. These changes will make this procedure compatible with SP 1302- The TMI-1 Restart-Staff concluded that the two proce-dures were inconsistent; and, because of the frequency at which personnel' implemented these procedures, facility per-sonnel neglected to formally initiate a change to the pro-cedure. The actual steps performed were technically correc .2.5.2 On November 5, 1985, an NRC shift inspector observed an operator remove a circuit board related to annunciator win-dow B-4-5 on the heating and ventilation panel. The opera-

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tor did this to clear an annunciator " nuisance" alarm to prevent unnecessary distractions while attempting to place the B main feedwater pump in automatic. The TMI-I Restart Staff observed this practice throughout the startup testing period since October 3, 198 The NRC shift inspector ques-tioned why an out-of-service tag was not placed on the an-nunciator because removal of the circuit board places an alarm input in an out-of-service (00S) conditio The TMI-1 Restart Staff reviewed AP 1036, Revision 6, February 10, 1985, " Instrument Out-of-Service Control."

Paragraphs 3.1.1.a to e of the procedure required that, if an instrument was out of service for more than a shift, the instrument out-of-service condition was to be

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6 logged in the out-of-service log with the appropriate sticker affixed to the instrument. However, parag'raph 3.1.1.d required that the 00S sticker was to be affixed to any alarm window in which the alarm circuitry was disabled for maintenanc The operator's action noted'above was not. exactly for main-tenance; and in actuality the procedure did not address preventing a nuisance alarm. When questioned, licensee representatives indicated that past practice was to use the more than a shift criterion for placing the instrument in the 00S lo The inspector reviewed controls that would remind operator that an instrument was 00S. The controls should result in the proper recording of the 00S condition and the turnover of that information to the next shift. The inspector con-firmed that the control room operator turnover checklist provided for 00S entrie The inspector concluded that the licensee's procedure was not clear on the handling of nuisance alarms and licensee representatives had not initiated a change to the procedure prior to this time to update the procedure to current practic .2. On October 30, 1985, the shift. inspector observed the high neutron flux reactor trip calculation and instrument set-ting (based on heat balance) in accordance with SP 1303-4.1. Page 17 of the procedure. required that the shift supervisor indicate approval of the calculation by signing i

approval on the space provided. When questioned by the

. shift inspector, the shift supervisor (SS) was not sure when the SS was to sign regarding the following options:

(1) after the calculation and before instrument setting, or (2) after calculation and instrument setting. The licensee's operations staff indicated that option (2) was require Based on the inspector's review of the procedure, it ap-peared that option (1) was require The. inspector concluded that the procedure was not clear'as to'when the shift supervisor's signature was require Further,~in spite of the numerous. times this procedure sec-tion was implemented, licensee representatives had not ini-tiated a change to the procedure to enhance its clarit _ _ - . - _ _ _ _ - _ _ - _ _ _ _ _ -

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3.2.5.4- Between November 7 and 10, 1985, the.NRC shift inspector selectively verified that proper valve / breaker positions were in accordance with the. licensee's locked valve list, as required by AP 1011. The inspector found no valves mis-positioned. However, he found core flood valve CF-V-3B breaker not properly locked. The operator properly locked the breake The TMI-1 Restart Staff reviewed administrative procedure AP 1011, Revision 24, July 7,1983, " Controlled Key Locker Control." The procedure provides no guidance on how to check valves or breakers to determine if they are properly locked. Further, there was no provision to periodically verify the list during power operations. The mechanical and electrical lineup operating procedure for CF-V-3B does not require the breaker for.CF-V-3B to be locked. This operating procedure and others do not required independent verification of valve lineups if performed such as for startup after a major outage. Based on previous NRC review in this area, restart valve lineups were properly conducte The inspector concluded that AP 1011 lacked clarity, over-

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all, on exactly how to implement locked valve controls aside from isolated valve / breaker repositioning for infre-quent special evolutions / tests or preventive / corrective-maintenanc Further, existing administrative controls on independent verification of proper valve / breaker positions were mini-mal; i.e., removing and restoring equipment.to service in meeting TAP I.C.6 requirements, as described in NUREG-0578 and NUREG 0737. Had additional or clearer controls been i place, .the improperly locked CF-V-3B breaker might have been detected upon independent verification (see paragraph '

3.2.5.5).

3.2. During the setting of the liquid radiation monitor RM-L6 interlock for discharge isolation on November 1, 1985, the shift inspector observed that the I&C technician reposi-tioned a " slide link" (or essentially lifted or discon-nected electrical leads). The shift inspector questioned whether or not an independent verification of that action (on removing or restoring to service) was warranted. The TMI-1 Restart Staff reviewed administrative procedure (AP)

1013, Revision 17, October 23, 1985, " Bypass of Safety Function and Jumper Control." Paragraph 1.3.A.2 required that, for evolutions involving electrical jumpers, lifted leads, or temporary mechanical modifications, entries into the applicable log were not needed provided that the shift supervisor was informed and a properly approved procedure

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which initiated a 10 CFR 50.59 review was used. This ap-plied to important-to-safety (ITS) systems and manipula-tions to an ITS system were required by~0P 1104-29 However, that procedure did not require independent verifi-cation of the movement of the slide link for setting the RM-L6 setpoin 'The inspector concluded that OP 1104-29S was inconsistent with AP 1013 requirements. Further, licensee management initially responded that AP 1013 was not reflective of com-mitments to NRC on independent verification because ITS systems are a broader classification of systems as com-pared to safety-related systems, as defined by the licensee's operational quality assurance plan. Licensee representatives agreed to review this-matte Licensee commitments and implementation for independent verification is unresolved pending completion of licensee action as stated above and subsequent NRC Region I review (289/85-26-02). ,

3.2. Between November 1 and 8, 1985, the shift inspector verified proper calibration of instrumentation used to per-form the RCS leakrate calculation. During this review,-the shift inspector identified that the manual method (if the plant computer is unavailable) could use a general form for makeup tank and reactor coolant drain tank (RCDT) tempera -

ture and one procedure step called for the recording of makeup tank or RCDT temperatur Steps later in the form do not use RCDT temperature since.the calculation assumed 120-140 degrees F in the RCDT. The step calling for RCDT temperature could be confusing to the operator but the in-spector did not consider it significant in that it would not preclude satisfactory completion of the manual calcula-tion. The' inspector had no further comments on the -

procedur Similarly SP 1301-8.2, " Diesel Generator Annual Mainte-nance," paragraph 6.3.5 and 6.3.6 erroneously referenced preventive maintenance procedure E-38 as the frequency me-ter calibration procedure and E-39 as the voltmeter cali-bration procedure, respectivel In actuality, they were reversed but it did not preclude the satisfactory comple-tion of the required procedure.-

3.2.5.7 On November 2, 3, and 10, 1985, during a radioactive waste gas tank discharge, the shift inspector identified a fail-ure to meet a procedural step. Paragraph 3.7.2.5 of OP 1104-27, Revision 34, October 31, 1985, " Waste Disposal-Gaseous," required that_an operator position an appropriate sign, " Gas Release in. Progress," at the auxiliary building and control room liquid waste disposal panels. They posted

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the sign at the radwaste panel in the auxiliary building-as required by the procedure but not in the control roo Two shifts were involved in the three incidents observed and in each case the NRC inspector identified the failure

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to comply with the procedure step. The procedure step was also signed off as complete, apparently only because the

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auxiliary building ' sign was poste The' posting of the sign in the control room was a licensee initiative to highlight to operators that the evolution was in progress. The inspectors concluded that the failure to comply with the procedural. step was minor in nature. How-ever, the repetitive failures to comply could not be considered an isolated cas .The inspector concluded that, for the above instances, shift personnel had not demonstrated the initiative or at-tention to detail to take effective corrective action to assure-implementation of the procedurally directed steps desired by licensee managemen .2. In summary, many of the procedural steps reflect licensee initiatives to properly control the evolutions dictated by these procedure Each of the above items can be grouped into the following categories: failure of personnel to strictly adhere to individual procedural steps; failure of personnel to assure that each procedural step adequately meshes within its procedure or is consistent with a refer-enced procedure; and/or failure of field personnel to con-scientiously provide feedback to licensee management for procedure improvement. Although each personnel performance shortcoming was minor in nature, collectively they raised concerns by NRC staff members as to whether or not an un-derlying problem existed within the licensee's organiza-tio Licensee representatives stated that, in their opinion, personnel performance has been good overall; however, corrective actions would be taken. The TMI-1 Re-start Staff considered this area to be unresolved pending additional review by the staff (289/85-26-03).

3.3 Conclusion Licensee management and their quality assurance department continued their detailed attentiveness and involvement in daily activitie 'Although some communication lapses occurred, they were considered minor and they had no adverse affect on the facility. The material condition of the facility remained quite good and the licensee demon-strated control of fire hazard loading as noted in the review of that area in the turbine buildin It was noteworthy that the licensee was essentially on schedule with their power escalation program and that the per formance of equipment and personnel had not resulted in a pla.nt trip or challenge to other safety-related equipment.

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e Ine procedure implementation problems were indicative of a poten-tially adverse trend. Considering the number of procedural steps implemented at the facility on a daily basis, the NRC-observed prob-lems might be considered statistically insignificant, and they were individually minor problems. However, the TMI-1 Restart Staff con-siders that these problems may be indica'tive of a more fundamental proble Licensee management may need to focus additional attention on this area. The TMI-1 Restart Staff will continue to review this along with how the licensee conducts independent verifications in the next . inspection perio Further, the TMI-1 Restart Staff will continue to review the design adequacy of the relief valve between the reactor building wall and the primary containment isolation valves in the NSCCW syste . Radioactive Water Spill in Makeup Pump Cubicle 4.1 Event Chronology On October 28, 1985, between 4:20 and 4:30 p.m., approximately 150 gallons of primary water spilled in the "A" makeup pump cubicle. The plant was at steady-state 48*s power and the reactor coolant system was at normal operating temperature and pressur Auxiliary operators (A0s) were to isolate and drain makeup pump MU-P-1A to repair a leaking drain plug in the discharge line. This task was to be accomplished by using switching order 85-1672. After the isolation valves were positioned and tagged in accordance with the switching order, the pump casing drain in the cubicle was opene '

Water then began to flow into the floor drai At this time, the control room operators noticed a decreasing level in the makeup tank, MU-T-1. Before the shift foreman could tell the A0s to close the drain valve, local radioactivity airborne monitoring system AMS-3 alarmed in the MU-P-IA cubicle. The A0s exited the cu-bicle and the drain valve was left ope Within ten minutes, the A0s re-entered the cubicle to shut the drain valve. Water was running off the skid, which supports the pump and motor, on to the floor because the floor drain was apparently clogged. The A0s shut the drain valve and the decreasing level in MU-T-1 stoppe The shift supervisor dispatched the_ shift foreman to the auxiliary building where he verified the switching order as being correct and the isolation valves were recycled. A second attempt to drain the pump was made at 8:00 p.m.; this attempt failed. The shift supervi-

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sor ordered a suction cross-connect valve to be closed to provide double isolation from MU-T-1. A third attempt to drain MU-P-1A was i made;'this attempt was successfu .

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Auxiliary building airborne radioactivity levels remained higher than normal but still below RM-A 4, 6 and 8 alarm setpoints from 4:30 to 11:00 p.m. However, AMS-3 alarms were received in the Unit 2 fuel handling building. The reasons for the Unit 2 alarms are due to in-terconnection of the fuel handling buildings and their ventilation system Radiological engineers estimated approximately 0.7 Ci of noble gases (mostly Xe-133) was released; the dose calculations at the site boundary was estimated to be O'.002% of the federal quarterly limit for the noble gas released to the environment from the plant's ventilation syste .2 Scope of Review The inspectors reviewed the details of the spill and the licensee's review of this event to determine:

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details regarding the cause of the event and event chronology;

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consistency of licensee actions with NRC license and procedural requirements; and,

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proposed licensee actions to correct the cause of the even The inspectors' review of this incident included discussions with cognizant licensee personnel and review of the following documents

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system drawings

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CR0 and SF logs

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Switching Order 85-1672

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Surveillance Procedure 1101-2.1, Revision 16, dated October 28, 1985

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. Administrative Procedure 1044, Revision 14, dated June 4, 1985

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various radiological data and calculations

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critique meeting minutes The inspectors also attended the radiological investigative critique that was held on October 29, 1985, and conducted inspections of the MU-P-1A cubicle.

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4.3 Licensee Findings / Actions The cause of the event was leakage past closed suction valve MU-P-72 The event was complicated by a clogged floor drain and the A0s exiting the cubicle 'without closing drain valve MU-V-172A after AMS-3 alarme The licensee determined that radioactivity levels

- were greater at RM-A4 as compared to RM-A6 because the upper level fuel handling building ventilation system draws air from the Unit I side of the building including the exhaust header. Since radiation levels did not get high enough to isolate the fuel handling building dampers, the noble gas also dispersed to TMI- Nine workers were slightly contaminated with short-lived radioactive particulate daughter products; principally, Rb-88. Personnel exposure was derived'from both isotopes. However, within ninety minutes the contamination had decayed away. Whole body counts of the individuals involved identified no substantial change from the baseline whole body coun As part of the licensee's follow-up actions, this event will be re-viewed with each of the operations crews. Work requests will also be initiated to repair MU-V-72A and the clogged floor drain; MU-V-72A will also be caution tagged. Grab samples in the area during the event identified noble gas radioactivity as the primary constituent; i.e., XE-133, Xe-133m, and Kr-88. Such activity indicated that. valve leakage was occurring probably from MU-V-72 Total release due to the event was estimated to be about 6.77 E5 uCf, resulting in approximately 7.39 E-5 mrad gamma air dose and 8.69 E-5 mrad beta air dose as compared to the quarterly limits of technical specifications; i.e., 5.0 mrad and 10.0 mrad respectivel The job was completed without specific procedural coverage using a standing radiation work permit (RWP). The licensee immediately re-vised standing RWPs to assure that radiological controls personnel were contacted if systems were to be opened on a standing RW Licensee management indicates that standing RWPs would not be used in the future to drain open systems containing radioactive materia .4 NRC Finding Licensee action of self review was appropriate and reasonably thor-oug However, based on the above review, the inspector found some items of concern. Operations personnel did not close the drain valve before evacuating the makeup pump cubicle, and their use of a stand-ing RWP caused radiological controls personnel to be unaware of the draining operation.

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The licensee's radiological incident report (RIR) was to be finalized by the operations department along with prepared corrective action This area is unresolved pending issuance of the RIR by the licensee

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and subsequent TMI-1 Restart Staff review (289/85-26-04).

4.5 Conclusions

, The operators' response at the cubicle was poor in that they failed L

to isolate the leak before evacuating the makeup cubicle. Contral room operators were responsive to the symptoms noted in the control room. Critique review and actions were appropriate for the circum-stances. The TMI-1 Restart Staff will review the completed RIR and

> licensee corrective action . Nuclear Plant Staff Working Hours The inspector conducted a review of the overtime expenditure for.certain operating personnel, including senior reactor operators, reactor opera-tors, and radio. logical controls personnel for the period September 30 through October 27, 1985. The licensee is required to limit overtime-use in accordance with Administrative Procedure (AP) 1031, and Technical Specification (TS) 6.8.1. This subject was previously reviewed by Region I as discussed in Inspection Report 50-289/85-08, dated March 8, 1985, which verified-licensee awareness of the requirements and compliance to AP-1031 and Generic Letter No. 82-1 The inspector determined that no onshift SR0s, R0s or radiological control personnel exceeded AP-1031 policy limits during the above period. In some instances personnel were required to work hours that were close to the weekly limits of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />'in a 7 day work week. This was due to the

. training required for restart activities for licensed operators. The licensee does maintain a sufficient staff of licensed personnel (six full shifts) to. permit compliance with Commission policy that encourages a 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, 5 day work week, with overtime use on only rare occassions. The licensee is encouraged in the. future to plan training evolutions in ad-vance of other activities to' alleviate the use of excessive overtime and long work periods for licensed operator The inspector had no further comments in'this are . Diesel Generator Maintenance 6.1 Background The emergency diesel generator (EG-Y-1A) was isolated for the annual preventative maintenance inspection on November 4, 1985. The licensee entered a seven day action statement in accordance with Technical Specification (TS) 3.7.2.c which requires that the operable diesel be run immediately and daily during the period when the other diesel is inoperable. If the diesel generator cannot be made opera-ble within the seven day period the reactor must be shut dow _ _ _ _ _ _ _

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6.2 Scope of Review The following procedures, manuals and documents were reviewed by the inspector during the course of the maintenance inspectio Technical Specification Section 3.7, " Unit Electr1tal Power System"

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Maintenance Procedure (MP) 1405-3.2, Revision 7, " Diesel Genera-tor Maintenance"

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Operating Procedure (0P) 1107-3, " Diesel Generator Operation"

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Surveillance Procedure (SP) 1301-8.2, " Diesel Generator Annual Inspection"

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SP 1302-5.30, " Diesel Generator Electrical Inspection"

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SP 1303-4.16, " Electrical Power Systems" During'the course of the maintenance the inspector observed selected portions of the mechanical and electrical surveillance activ.itie These included removal, testing, reinstallation of injectors, inspection of cylinder wall for water leaks, pressure switch setpoint checks, generator brush replacement, and cooling water check valve inspection. The inspector observed vendor representative and QC/QA involvement during the inspection proces .3 NRC Findings The inspector verified that the operaM.e diesel (EG-Y-18) was tested at the required frequencies and that the licensee maintained the re-quired systems, subsystems, trains, and components that depend on the operable diesel generator in an operable condition as required by technical specifications. This was accomplished based on shift in-spector review of the licensee's engineered safety features /emer-gency feedwater operability checklis The licensee discovered two minor problems during the inspectio The first was a small engine coolant leak from the cylinder cooling jacket lower end to the engine crankcase. This type of leak was con-sidered acceptable by the licensee and vendor personnel and would not result in any engine damage during operation, or prevent proper starting of the diesel. The licensee plans to increase sampling fre-quency of the diesel lube oil for presence.of water from the normal six-month period to weekly to assure that there is no excessive water buildup in the lube oil system. The inspectors concurred with this action and had no questions on the subject. The inspectors will re-view licensee action on thi; subject in future inspection '

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The second problem occurred with check valves that were removed from the diesel cooling systems. These valves were required to be in-spected in response to IE Bulletin 83-0 The licensee determined that valve EG-V48A, had a rubber valve seating surface that was slightly rippled and could possibly cause improper seating of the valve. In conjunction with the licensee's plant engineering depart-ment review of this valve, the maintenance department determined that this was an acceptable condition and the valve would function proper-ly but no written documentation was issued on this review other than the as found condition on the procedure data sheet. The inspector concurred with this action and had no further questions. The inspec-tor will examine diesel engine standby heating operation in future inspections to ensure proper operation of this check valv The shift inspector obses.ad that, after removal from the system,

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check valve EG-V48A wrc .* en approximately 20 degrees. The check valve has butterfly type iscs that are intended to be 90 degrees full open or 0 degrees full closed (by spring action) depending upon

. system operating ,:ondition. The licensee organization did not con-sider this to 'be a problem since the maintenance record, and plant inspection reports do not reflect this as found condition and there-fore, there was no engineering evaluation on the condition. Based on inspector judgement, it appeared that the valve would seat closed on reverse flow differential pressure, so no concern was identified for the operability of the check valv The check valve prevents " keep warm" system water from being diverted to thel radiator section of the cooling water system thereby prevent-ing inadvertent cooldown of the system. The as found condition will be reviewed further by NRC Region I during the next inspection period related to the B. diesel maintenance (289/85-26-05).

The inspector observed the licensee QA and QC coverage during the inspection. QA personnel were present and observed that selected tests and actions performed by maintenance personnel were conducted in accordance with the applicable procedures. The QA/QC personnel are alerted to the performance of maintenance on safety-related equipment by a memorandum from the maintenance departmen This al-lows the QA/QC personnel to perform their audit function on a random basis. The surveillance procedures do not contain any specific hold points where QA/QC would be required to verify any critical data that were to be recorded. This would only be accomplished if the QA/QC personnel were present at the correct tim The inspector feels that the maintenance and surveillance procedures that accomplish poten-tially critical work on the emergency diesel generators should be reviewed in advance of performance to identify in the procedure any critical data points requiring independent verification by QA/QC per-sonnel, vice the random method that is now employed. Although the QA/QC coverage appeared to be satisfactory based on inspector obser-vations, an independent evaluation of critical data should be made by senior QA personnel and reflected in the procedure.

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6.4 Conclusion The annual in,spection of emergency diesel generator 1A was accom-plished in a manner'that would ensure proper operation of the diese Vendor involvement and QA/QC coverage were acceptable. .A review of the completed maintenance package and test results will be conducted by the TMI-1 Restart Staff' subsequent to the B diesel outag . Safety-Grade Emergency Feedwater Inplant Review On November 7, 1985, members of the TMI-1 Restart Staff inspected spaces in the intermediate and diesel generator buildings which housed a major portionuof the emergency feedwater syste The purpose of the inspection was to identify to members of the Office of Nuclear Reactor Regulation items of concern in which there was a potential that the system design would not meet the safety grade criteria embodied in the General Design Criteria (10 CFR 50, Appendix A) and related guidance in the NRC staff's standard review plan. The inspection consisted of a flow path walkdown along with the identification and system description of major components and support system components such as the 2-hour backup air supply syste As a result of this review, a number of questions were formulated by the staff to be considered by the licensee (Attachment A).

-These and other items were discussed with licensee representatives at an interim exit meeting on November 7, 1985. Licensee representatives agreed

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to submit a report on'the resolution of the inadvertent actuation of the steam ~ relief valves (MS-V22A/B) to the EFW turbine (Inspection Report 50-289/85-22). The Technical Specification Table 4.1-9 for EFW valve lineup will be updated prior to cycle 6 startup. (The operating procedure assures proper EFW valve alignment.) The licensee plans to make the re-dundant block valves manual valves instead of automatic. The staff indi-cated that this is a significant change in commitment which will be need to be evaluated by the staff. The staff accordingly urged the licensee to

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make the submittal on this issue as soon as possibl . Exit Interview The inspectors discussed the inspection scope and findings with licensee management at the exit interview conducted on November 12, 1985. The following licensee personnel attended the final exit meeting:

J. Colitz, Plant Engineer Director, TMI-1 T. Hawkins, Manager, TMI-1 Startup and Test, Technical. Functions H. Hukill, Vice President and Director, TMI-1 C. Incorvati, TMI-1 Audit Supervisor, Nuclear Assurance G. Kuehn, Manager, Radiological Controls TMI-1, Radiological and Environmental Controls S. Otto, TMI-1 Licensing Engineer, Technical Functions L. Ritter, Administrator II, Plant Operations, TMI-1

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M. Ross, Manager, Plant Operations, TMI-1 D. Shovlin, Manager, Plant Maintenance, TMI-1 C. Smyth,.TMI-1 Licensing Manager, Technical Functions

. . Toole, Operations and Maintenance Director, TMI-1-The exit. meeting was also' attended by S. Maingi, a nuclear engineer repre-senting-the Commonwealth of Pennsylvania. The inspection results, as dis-cussed at the meeting, are summarized in the cover page of.the inspection-repor Licensee representatives indicated that none of the subjects dis-cussed contained proprietary informatio Unresolved items are matters about which information is required in order to ascertain whether.they are acceptable items,. violations, or deviation Unresolved item (s), discussed during the exit meeting, are documented in paragraphs 2.2.2, 3.2.3, 3.2.5.5, 3.2.5.7, 4.4, and *

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ATTACHMENT A REQUEST FOR ADDITIONAL ~INFORMATION TMI-1 EMERGENCY FEEDWATER SYSTEM MODIFICATIONS 1. . Confirm that ducting, piping.and other components that could potentially impact the backup instrument air bottles in the diesel generator room are either seismically supported or, if not, that their failure would not re-For equipment that is

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sult in loss of function of the backup air bottle ' seismically supported, provide the criteria used to establish seismic ~

qualification (e.g. Regulatory Guide 1.29). Provide a discussion which justifies the proposal-to change the failure

. mode for the new emergency feedwater flow control valves (EF-V30s) to-closed rather than open on loss of air. This discussion should address

'the importance of assuring reliable emergency feedwater flow against other considerations such as overcooling / overfillin . Describe those' features (indications) and actions relied on to alert the operators of flooding in the tendon access gallery in the intermediate building, for example, as a result of a main feedwater line break, Speci-

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fy'the design basis for.these features. This discussion should also ad-I dress the actions taken in the event of inadvertent indication of flooding L and'an assurance that these actions will not cause unnecessary challenges

! to safety system . What are the additional hazards and/or effects on safety-related systems in the intermediate building (especially the emergency feedwater system)

with the storage of hydrogen and oxygen calibration gas bottles in the vicinity of safety-related equipment?

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