IR 05000289/1986022

Safety Insp Rept 50-289/86-22 on 861205-870109.No Violations Noted.Major Areas Inspected:Outage Activities,Including Operation,Maint & Surveillance Areas,Refueling Preparation & Loss of Vital Bus 1E

ML20212L270
Person / Time
Site:	Crane
Issue date:	03/02/1987
From:	Conte R, Dante Johnson, Young F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20212L231	List: IR 05000289/1986022 ML20212L228
References
50-289-86-22, NUDOCS 8703100328
Download: ML20212L270 (22)

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION I

Report No.

50-289/86-22 Docket No.

50-289 License No.

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 Inspection At:

Middletown, Pennsylvan.ia

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Inspection Conducted:

December 5,1986, to January 9,1987 Inspectors:

H. Bicehouse, Radiation Specialist, RI D. Johnson, Resident Inspector (TMI-1)

A. Lodewyk, Reactor Engineer, Region I M. Miller, Radiation Specialist, RI J. Prell, Reactor Engineer, RI J. Rogers, Resident Inspector (TMI-1)

F. Young, Senior Resident Inspector (TMI-1)

Reporting Inspector:do-D. JohnsopfAesidsnt Inspector (TMI-1)

2-I N Date Reviewed By:

M-9 )

' F. Younge:$ nior Resident Inspector (TMI-1)

Date Approved By:

["A k

3-2-J)

R. ConA((Chief Date Reactor Projects Section No. lA Division of Reactor Projects Inspection Summary:

Resident at:d region-based NRC staff conducted safety inspections (270 hours0.00313 days <br />0.075 hours <br />4.464286e-4 weeks <br />1.02735e-4 months <br />)

of outage activities, focusing on plant and personnel performance.

Specifically, items reviewed in detail in the operation, maintenance, and surveillance areas were:

refueling preparation, and loss of the IE vital bus. Other items included:

reactor coolant pump (RCP) seal repairs, Fuel Handling Building (FHB) Engineered Safety Features (ESF) ventilation system installation and testing, Inservice Inspection (ISI) program review, Appendix R inspection, radiological water chemistry review, and licensee action on previous inspection findings.

8703100328 870302 DR ADOCK 05000289 PDR

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Inspection Results:

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For the activities sampled, the inspectors noted that, in general, the licensee properly completed evolutions and completed maintenance / surveillance activities consistent with regulatory requirements.

Refueling evolutions were conducted safely, ESF_ ventilation testing was thorough and complete. RCP seal replace-ment activities were satisfactory but further evaluation of seal failure needs to be made by the licensee.

Radiological water chemistry activities appear to be acceptable and the conduct of outage ISI activities were being accomplished satisfactorily. No violations of NRC requirements were observed. The licensee action on previous inspection findings was acceptabl. _ _ _ _ _ _.

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DETAILS I

1.

Introduction and Overview 1.1 NRC Staff Activities The overall purpose of this inspection was to assess licensee activities during the cold shutdown mode as they related to reactor safety and radiation protection. Within each area, the inspectors documented the specific purpose of the area under review, scope of inspections, along with appropriate conclusions. The inspector made this assessment by reviewing information on a sampling basis through actual observation of licensee activities, interviews with licensee personnel, measurement of radiation levels, or independent calcula-tion and selective review of listed applicable documents.

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During this period, region-based inspections were completed in the areas of radiological water chemistry and inservice inspection (ISI)

program.

During the week of December 15-19, 1986, representatives from the NRC Office of Nuclear Reactor Regulation (NRR), Region 1, and contract personnel performed an audit of the licensee's compliance with 10 CFR 50 Appendix R.

A resident inspector assisted team members in this review. The areas reviewed included:

emergency lighting; safe shut-down capability including alternate safe shutdown for a fire in the relay or control rooms; individual fire zone modifications including smoke detection, fire suppression systems, cable rerouting, shielding, and damper installation to adhere to the Fire Hazards Analysis Report (FHAR); subsequent NRR Safety Evaluation Reports (SER's); associated circuits analysis; and, manual valve actions required for safe plant shutdown. Several strengths and deficiencies were identified during the audit and are detailed in Inspection Report 50-289/86-23.

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1.2 Licensee Activities During this period, the licensee maintained the plant in cold shutdown.

Preparations for fuel shuffle were underway with the repairs to the

"A," "C," and "D" RCP seals being completed.

The Fuel Handling Building Engineered Safety Features ventilation system installation and testing were completed.

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Plant Operations l

2.1 Scope of Review

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l The NRC resident inspectors periodically inspected the facility to l

determine the licensee's compliance with the general operating l

requirements of Section 6 of the Technical Specifications (TS) in the l

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;

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control of ongoing and special evolutions, including Control

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Room personnel awareness of these evolutions;

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control of documents, including logkeeping practices;

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implementation of radiological controls;

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implementation of the security plan, including access control,

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boundary integrity, and badging practices; and, implementation of the fire protection plan, including fire

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barrier integrity, extinguisher checks, and housekeeping.

Because of additional resident inspector coverage at this facility, more detailed and frequent reviews of operating personnel performance were conducted to determine that:

operators are attentive and responsive to plant parameters and

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conditions; plant evolutions are used and followed as required by plant

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policy; equipment and status changes are appropriately documented and

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communicated to appropriate shift personnel; the operating conditions of the plant equipment are effectively

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monitored and appropriate corrective action is initiated when required; backup instrumentation, measurement, and readings are used as

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appropriate when normal instrumentation is found to be defective or out of tolerance; logkeeping is timel/, accurate, and adequately reflects plant

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i activities and status; f

l operators follow good operating practices in conducting plant

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operations; and, operator actions are consistent with performance-oriented

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training.

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Specifically, the inspectors focused attention on the areas listed below.

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General / Operations

Control Room operations during regular and backshift hours,

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including frequent observation of activities in progress, and periodic review of selected sections of the shift foreman's log and Control Room operator's log and other Control Room daily logs Areas outside the Control Room, including important-to-safety

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buildings Refueling Operations

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Selected licensee planning meetings

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Maintenance Fuel handling equipment repair

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DHV-5A and DHV-14A repair (disc replacement)

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EG-Y-1A - emergency diesel generator yearly maintenance

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As a result of this review, the inspectors reviewed specific areas in more detail as described in the sections that follow.

2.2 Finoings 2.2.1 Refueling Operations Refueling operations commenced on January 2,1987, and were in progress at the completion of the inspection period. Minor problems with the control rod handling mast on the main fuel handling bridge had delayed refueling operations while repairs were made. No major problems were experienced although some fuel assemblies would bind up with adjacent assemblies during removal, necessitating extra time to unbind and extract the assemblies from the core. This was not considered to be a major problem as some bowing and binding of the fuel assem-blies is expected.

(The NRC refueling preparation review was documented in Inspection Report 50-289/86-21.)

The inspector witnessed the movement of fuel assemblies in the Reactor Building (RB), monitored the tracking and control of fuel assemblies from the Control Room (CR), verified that Operational Quality Assurance (0QA) was monitoring the refuel-ing operations on a 24-hour basis, and toured the spent fuel pool are _

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From these activities, the inspector determined the following.

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-- The licensee had established a housekeeping program in the spent fuel pool and reactor pool areas. The inspector found one problem with housekeeping in the RB on the D-ring level where health physics had established a monitoring station. Paper trash was left lying loosely on the floor and on equipment carts. These items could have easily fallen into the refueling pool.

The licensee immediately corrected this situation.

-- The main and auxillary fuel handling bridges limit switches actuated properly at the designated setpoints.

-- The movements of the fuel and the refueling bridges were under the direct control a senior reactor operator (SRO)

who had no other concurrent duties or responsibilities.

-- The staffing levels for the spent fuel pool area, the Control Room, and the Reactor Building met programmatic and technical specification requirements.

-- Direct communications had been established between the Reactor Building, the spent fuel pool area, and the Control Room.

-- An audio speaker system had been established and in use in the Control Room for monitoring the source range detectors.

-- Samples were being taken daily from the refueling pool to verify that the boron concentration levels were above technical specification requirements.

-- Radiation and airborne radioactivity monitors were oper-able, in use, and calibrated.

-- Nuclear engineers were in the Control Room monitoring the placement of all fuel assemblies, performing 1/M calcula-tions after each assembly movement, and determining the placement of new fuel assemblies.

-- Quality Assurance (QA) personriel were present and were monitoring and auditing refueling activities. The inspec-tor also verified that Operational Quality Assurance personnel (0QA) were monitoring refueling activities on a 24-hour / day basis by reviewing the Quality Assurance Monitoring Report Log. The adequacy of the monitoring activities was determined by reviewing the monitor's check-list and the Shift Refueling Operations Summary list.

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The inspector concluded that refueling operations were being carried out in a safe manner. Personnel conducting the evolu-

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tion appeared qualified and QA coverage was adequate. Although the refueling equipment problems have caused. delays, no adverse affects on fuel movement or control rod changeout were noted.

No violations or unresolved items were identified.

2.2.2 Loss of IE 4160 Volt Bus On January 9,1987, the licensee experienced a loss of the IE 4160 VAC vital bus. At the time, the 18 decay heat system was being powered from this bus. This included the "B" decay heat pump DH-P-1B, decay heat closed-cooling pump DC-P-18, and the decay heat river water pump DR-P-18. All pumps stopped running when the bus was de-energized.

Refueling fuel shuffling oper-ations that were in progress were secured.

The licensee investigated the problem and determined that contractor personnel working in the breaker cubicle for the IE cross-tie breaker to the 10 vital bus had lifted a lead that apparently caused an over-current trip signal for the IE bus to be generated. This resulted in the trip of the feed breaker to the bus.

The licensee cleared the over-current signal and re-energized the bus. The bus was de-energized for approxi -

mately fifteen minutes. Subsequently, the decay heat system

"B loop" was returned to normal operation. The IB emergency diesel generator started automatically as designed but did not load onto the bus as the over-current signal was present.

This prevents the diesel from being connected to a faulted bus.

Control Room personnel responded properly to the event, which was monitored by the inspectors who were present in the Control Room.

The licensee will review the event in a Plant Incident Report (PIR) to be issued at a later date.

The inspector concluded that the licensee satisfactorily responded to loss of the IE bus in accordance with their procedures. A proper evaluation of the 1E bus condition was made prior to re-energization. The inspector had no safety concerns with operator action during this event but will review licensee corrective action as documented in the PIR at a later date. This item remains unresolved pending NRC review of licensee's evaluation (289/86-22-01).

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Fuel Handling Building Engineered Safeguard Features Ventilition Shtem o

Testing

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-3.1 Background e'

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The licensee was required to install an ESF ventilation system for the fuel handli.ng building as a result of the TMI-1 restart hearing.

The ventilationi system was to be installed and operable prior to hel

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movement during the 6R refueling outage. The system war. to be designed in accordance with:the requirements of Regulatory Suide"1).52 and tested in accordance with the requirements'of ANSI N510-1900. 's The NRC issued License Amendment No.122 to the license (No. DPR-50)

technical specifications that-specified the Limiting Conditions for-s Operations (LCO) and surveillance requirements fcf this system.

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The inspector conducted a rodiew of the above docume'nts and also I

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reviewed various licensee documentation pertaining to the installa-

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tion and testing of this system.

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The following completed procedures were reviewed:

Ellis & Watts Co., "HEPA Filter Bank In-Place Leak Test Procedure Ob

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for Air Filtration Unit K0257-17," Revision 0; Ellis & Watts Co., " Air-Aerosol: Mixing Uriformity Test Procedure

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for Air Filtration Unit K0254-h,: tuvistor 0; Ellis & Watts Co., " Carbon Ads rber Bank In-P'. ace Leak Test

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Procedure for Air Filtration Unit K254-18," Revii. ion 0;

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TMI-1 Test Procedure, TP-141/17, Revisick 0, " Fuel Handling A'

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Building ESF Ventilation Functional Test;"

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TMI-1TestProcedure, Revision.0,"TP-141/19, Revision 0,"F[el

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Handling Building ESF Air Cleaning System Performance Test;"

TMI-1 Test Procedure, STP-366/14. Revision 0, " Calibration of

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the FHB, ESF Ventilation Systen Temporary Radiation Monitor;"

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r Operating Procedure (OP) 1104-150, Revistok 0, " Operation of tra

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FHB ESF Ventilation System."

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3.2 Design Peguirements i

The basic design requirements for the FHB ESF ventilation syst u werel=" -l/ ^

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to provide a ventilation system with *edundant components; class IF'

vital powee supplies and be capable of drawing 5000 cfm from the-H:3.

A radiation monitor for noble gasses and sampling capability +or iodine and particulate matter was to be installed in the systs:n

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effluent line. The system was supposed to be designed so that i

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single failure of any component would not cause a loss of the whole 7) ; e j

system. The single failure criteria was evaluated in Inspection

e, Report 50-289/86-19 and found to be acceptable. The system was.

j required to' naintain a negative pressure with respect to the outside atmosphere on the operating floor of the FHB of both units in the f

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absener of any other ventilation systems. Overall, the system was

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designed to mitigate the consequences of a fuel handling accident in

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the FHB as discribed in the Final Safety Analysis Report (FSAR),

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Section14.y.2.1.,' Update 4,7/85.

3.3 NRC Finding

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The ins [ectors verified that, in general, the new FHB ESF ventilation I

system was installed in accordance with design requirements. The test pre d dures reviewed were complete and encompassed all required

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NRR in their safety evaluation for License Amendment No.122. The tests were accomplished satisfactorily in accordance with the test objectives.

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One discrepancy was noted. STP 141/19 was written to verify, that with one fan running and all other ventilation systems secured, the r

J FHB would be maintained at 0.125 inch water gauge (WG) negative

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pressure with respect to atmosphere. Testing verified that the best rt /,/ *

negati W p'ressure that could be obtained was approximately.02 to.04 M

inches WG.

The licensee concluded that their design objective was met;

[l i.e., maintain a negative pressure, although the contractor design

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i calculations showed that the system should have been able to maintain

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a 0.125-inch WG negative pressure. After discussing this matter with

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_ the NRR Project Manager, the inspector concluded that the negative pres wre requirement wts met although not within initial design

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iThe licensee is evaluating for possible modification to the FHB

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i-structure to obtain a better negative pressure. The inspector will

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review any. modifications or repairs in future inspections.

n Seccadly,'the licensee was unable to install the originally planned RM-A-14 radiation monitor. A temporary system was installed con-sisting of RM-A-5 Hi and Lo range noble gas monitor and RM-A-13 j.

iodina and particulate sampling equipment with a temporary sampling

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pump system.

The temporary radiation monitor was evaluated by the inspe: tor and determined to meet the design requirements. The

)icensee plans to install the original RM-A-14 radiation monitor

, 'when it arrives on site and it will be used during the next refuel-ing or for any other fuel handling evolutions in the future. The

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1nspector had no other concerns on the design and installation of the PiB ESF ventilation system. Unresolved item (289/85-20-03) was opened to track the review of this modification.

This unresolved item is closed (see section 7.3).

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3.4 Conclusion

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The: inspector. concluded that the FHB ESF ventilation system was

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designed and'installdd in accorddhce with all appropriate:

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requirements.h The1 licensee correctly implemented Technical Specifi--

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l cation Amendment No.'122. The licensee has'not written or approved

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. %y the.surveiltance procedures to be used as required in the technical.

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. specifications.

For.the initial installation, the test procedures'

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. referenced previously incorporated all the surveillance requirements.

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Sw evaluations'of the. surveillance test program..: Installation and-s mp testing for the system was completed only two days prior to use and, y

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although%some minor equipment discrepancies existed when the' system E

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~'h was. declared operable,1.these conditions did not adversely affect the '

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safe operation of th6 system!or prevent it from accomplishing-the N

design. objectives; The inspector had no'other. concerns.

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Reactor-CoolantPumpSealInspectio.bandReplacement

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During,the last operating cycle, both the "A" and:"C" reactor. coolant.

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" pumps (RCP's) exhibited abnormal" seal leakoff flow rates. The '"C" RCP

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No. I seal leakoff flow varied from 5-6 gallons per.' minute (gpm) during'

the -last 'several months-of operations (see Inspection Report 50-289/86-13).

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Normal No. 1 seal leakoff =is 2-3 gpm.? In October.1986, the "A" RCP No.

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-seal leakoff had decreased to 0.75 gpm as indicated in the Control Room i

(see Inspection Report 50-289/86-19).

In both cases, the licensee

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increased sealcleakoff monitoring.Y uring the current outage, the

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D clicensee has removed, inspectedmanderepaired the seal packages for both a

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the "A"~and "C" RCP's. The "Di RCP seal. package was'also removed for

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inspection. iThe_"B" RCP seal package was inspected during 1983 and no

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The No. lit sea 1Lis the' main seal.of the RCP and is a controlled leakage,

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film-riding face seal. Seal No.1 feals thk upper pump shaft against high pressure injections water, from the make-up and purification system,

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,which'is:used as a buffer to prevent reactor coolant' leakage past the

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.c pump l labyrinth seal.

In addition'to the No. l' seal',.each pump =is L"

equipped with a rubbing face No.'2" seal, which is also capable of operat-r ing at full system pressure should the~ No. I seal fail. A third rubbing

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face seal,is.p'rovided 'for low pressure sealing to prevent discharge into

the reactor containment.

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Because increased or' decreased seal leakoff)could indicate seal degrada-'

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. tion, the lice'nsee contacted the vendor to' perform an evaluation.

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make-up tank temperature, RCS pH, and No.~,1 ' seal leakoff data, the vendor.

y suggested that the cause of the abnormal leakoffs could be electrophoresis.

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' This phenomenon, purportedly, consists of the plating out of iron oxide

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particulates on the No. I seal ring face bevel allowing for greater or le'ss upward force to offset the seal injection pressure on the seal ring

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surfaces. The imbalances of forces on the seal surfaces allows a greater

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or 1 css seal leakoff flow.

For~the effect of electrophoresis to be l

possible, an electrical potential must exist across the sealing surfaces.

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The inspector _ conducted a review of the maintenance conducted on the "A" and "C" RCP seals. The following documents were reviewed:

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Job Tickets CK437 and CK-438; Maintenance Procedure (MP) 1401-1.1, Revision 13, dated November 17,

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1986, " Reactor' Coolant Pump Seal' Inspection and Repair;"

MP 1401-1.4, Revision 4, dated August 16, 1985, " Reactor Coolant

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Pumps and Motor Alignment;"

Electrical Corrective Maintenance Procedure 1420-RCP-6, Revision 0,

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dated April 2, 1985, " Removal and Adjustment of RC Pump Bentley Nevada Probes;" and, Change Modification Request (CMR) CM No. 0723M for upgrade of RCP

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No. 2 seal per Westinghouse Technical Bulletin NSID-TB-85-5.

These documents were reviewed for:

completeness and required administrative approvals;

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verification that QA hold points were ' identified and completed or in

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the process of being completed; verification that qualified replacement parts and tools were record-

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ed and identified;

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verification that the data sheets were properly completed;

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verification that acceptance criteria was defined and verified; and, verification that records were assembled, stored, and retrievable as

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part of the maintenance history.

The following items were found during the "A" RCP seal package inspection and replacement:

the No. I seal runner surface was coated with a red oxide layer

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(possible electrophoresis);

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the No. I seal ring surface contained a solid ring of purple matter 1/2-inch from the inside diameter (possible electrophoresis);

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the No. 1 insert showed signs of metal erosion; and,

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the No. 2 seal ring graphitar nose lip was gone (it appeared to have been worn away).

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The following. items were found by the licensee during the "C" RCP seal package inspection:

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- - - bright red solid oxide plating on both surfaces of the No.'1 seal (possible electrophoresis); and, the No. 2 seal ring graphitar nose: lip was gone (it appeared to have

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been worn away).

From the review of the above documents, the inspector determined that the repair.and inspections of the "A" and "C" RCP seals was performed per ap-plicable station administrative procedures. QA hold points were identified at the appropriate steps within the procedures insuring active involvement by the licensee's QA department. Qualified parts and tools were used to perform the repairs.

RCP seal data for maintenance history was taken and found to be within the established acceptance criteria.

From discussions with key personnel performing the work, the inspector determined that plant personnel possessed the adequate knowledge and skill to properly perform the repairs.

All damaged or worn parts were replaced and the seal packages reinstalled in the "A" and "C" RCP's. The licensee is in the process of decontamina-tion of the used seal package parts for shipment to the vendor for metal-lurgical and chemical analysis to determine the cause of the damage to the No. I and No. 2 seals. The damage to the No. 2 is significant because it would have been relied upon had the No. 1 seal failed during operation.

There was no obvious indication of damage to the No. 2 during power opera-tions. The cause of the damage to the No. I and No. 2 seals for the RCP's is unresolved pending completion of the licensed evaluation and subsequent Region I review (289/86-22-02).

The results of the metallurgical and chemical analysis, along with the review of the "D" RCP seal inspection package, will be reviewed in future inspection reports.

5.

Inservice Inspection Review The objective of the licensee's Inservice Inspection (ISI) Program is to provide assurance of the continuing integrity of the Reactor Coolant System while minimizing the radiation exposure of those personnel per-forming ISI activities. As required by 10 CFR 50.55a and as documented within the licensee's ISI program, the inservice inspection of ASME Code Class 1, Class 2, and Class 3 components is being conducted in accordance with the following:

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ASME B&PV Code, 1974 Edition Summer 1975 Addenda for selection of components and area of examination; ASME B&PV Code, 1977 Edition Summer 1978 Addenda for nondestructive

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examination techniques, calibration block design, and evaluation of indications; and,

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ASME~ Code Case N335-1 for IGSCC calibration block design and inspec-

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tion techniques.

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Specific relief from certain ASME Code requirements are documented within the licensee's ISI program and are currently under review by the-NRC Office of Nuclear Reactor Regulation (NRR).

The licensee's request to update certain portions-of the ISI program to later editions of the ASME is also under review by NRR.

An on-site inspection was conducted to ascertain whether the. licensee's ISI program, procedures, and work activities are consistent with regula-tory requirements and licensee commitments.

The inspection details are discussed in the following paragraphs.

5.1 ISI Procedure Review Throughout this inspection, the following procedures were reviewed, in part, for verification during observation of field work. Also, certain procedures (indicated by *) were reviewed for compliance with applicable portions of the ASME B&PV Code and for technical adequacy.

6110-QAP-7209.04, "VT-1 Visual Examination of Bolting;"

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• 6110-QAP-7209.06, " Manual Ultrasonic Examination of Stainless

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Steel Piping Welds;"

6110-QAP 7209.09, " Ultrasonic Examination of Studs and Bolting

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Using a High Gain Technique;"

• 6110-QAP-7209.23, " Wet Fluorescent Magnetic Particle Exanina-

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tion;" ISI PORD for Inservice Inspection;"

• Technical Specification (TS) SP-1101-12-102, " Pipe Wall-

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Thinning Inspection;" and, Short Form Specification SP-11-1-12-092, " Wall-Thinning Inspec-

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tion Locations."

The particular aspects addressed during the procedure reviews and during verification of nondestructive examination activities include:

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applicability and proper use of approved procedures; characteristics of equipment and material used;

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surface preparation, calibration, and nondestructive testing

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techniques; and, evaluation and documentation of examination findings.

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Those proceaures reviewed or referenced were found to be in agreement with ASME Code specifications and contained only a few minor clerical

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errors..ISI department and personnel responsibilities were clearly delineated within site administrative procedures. The outage ISI'

activity schedule was defined and GPU Quality Control personnel were actively involved in the daily ISI examination activities being performed by contractor personnel.

5.2 Observation of ISI Field Activities The following sample was selected for observation by the NRC inspec-tor from ISI examinations being performed during the sixth refueling outage.

The data gathering techniques and documentation associated with these examinations were reviewed for compliance with the applicable codes and administrative requirements.

Visual, ultrasonic and wet fluorescent magnetic particle

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examinations of Reactor Coolant Pump 8-inch bolts Ultrasonic thickness readings of extraction steam piping

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connections Calibration and ultrasonic examination of decay heat system weld

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Nos. DH-0074 and DH-0077 Based upon the above review, the inspector determined that the equip-ment and techniques utilized in the field were typically in agreement with those required by facility procedures and the ASME Code. How-ever, it was noted that within the facility procedures, administrative

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requirements have been added which may or may not facilitate the completion of a NDE procedure. Administrative requirements are deemed those site-specific procedure steps not required by the NRC or, by incorporation, by the' ASME Code for technical purposes. One example of this is found in procedure No. 6110-QAP-7209.06, " Manual Ultrasonic Examination of Stainless Steel Piping Welds." Procedure step 4.2.5.3 states:

"the examination area shall be cleaned (of couplant).with a demin-eralized water wipe upon completion of the examination for steel or nickel alloy systems which operate at elevated temperatures (i.e.,

150 degrees and greater)."

NDE certified technicians are not required by ASME or the NRC to be knowledgeable of the operating temperatures of the various plant systems. The procedure in question did not provide a reference in which technicians could determine which welds required couplant removal, nor was the information available within the scheduled outage plan. After examination of a decay heat system weld, the inspector noted the NDE technician did not remove the couplant as required by the procedure. When notified of this failure to complete

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the administrative requirement, the couplant was removed.

Licensee representatives stated an internal, informal review would be com-

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pleted to determine if this was an. isolated instance..The inspector agrees with the intent of the referenced procedure step which is to:

(1) help maintain plant cleanliness for safety; and, (2) discourage corrosion cracking in welds.

However, adequate guidelines and/or training is necessary for personnel to continuously and effectively complete all procedure requirements.

This item will remain open pending (1) further NRC review of a sample of site procedures for inclusion of administrative requirements which may lack adequate guidelines or personnel training and (2) a sample review of work activities which include completion of administrative procedural steps.

This is an unresolved item (289/86-22-03).

5.3 Supplemental ISI Activities Recently, the licensee has initiated a program to detect and evaluate pipe wall thinning caused by erosion / corrosion processes. The condi-tions used to select pipe locations for inspection include conditions conducive to erosion / corrosion such as high velocity, high steam moisture content, high fluid dynamic impingement forces, and pipe material. The program requires location candidates for severe erosion / corrosion to be inspected on a priority basis. During the sixth refueling outage, the inspector reviewed the prioritization analysis, data collection techniques, and computerized data compila-tion of suspected wall-thinning locations.

The inspector found the technical justification used for selection and prioritization of potential erosion / corrosion locations acceptable.

The ultrasonic measurement procedure details that the inspector veri-fled during field activities included instrument calibration, surface mapping and preparation and data recording. No deviations from proce-dural requirements were identified during the field inspections. The collected data, when compiled, identified areas of erosion / corrosion and will allow an erosion rate to be determined to assist in forecast-ing repairs. A number of components have already been removed from service as a result of ultrasonic thickness measurements.

The licensee's apparent efforts and initiative in implementing this program successfully are indicative of the facilities concern for component integrity and personnel safety.

6.

Water Chemistry Control Program 6.1 Background

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The licensee's water chemistry control program (as it related to controlling corrosion and out-of-core radiation field buildup) was reviewed relative to criteria, commitments, and recommendations provided in:

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Limiting Condition of Operation (LCO) 3.1.5, " Chemistry" and its

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surveillance requirements in Table 4.1-3 regarding minimum i

sampling frequencies; Condition 2.c(5) of License No. DRP-50 regarding a secondary

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water chemistry monitoring program;-

Licensee's letter (dated June 20,1985), H. D. Hukill, GPU

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Nuclear Corporation, to H. L. Thompson, Jr., NRC NRR, in response to NRC-NRR Generic Letter 85-02;

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Electric Power Research Institute (EPRI) Report NP-2704-SR, "PWR Secondary Water Chemistry Guidelines," Revision 1 (1984);

American Society for Testing and Materials (ASTM), Sect an 11,

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" Water Standards;" and, EPRI Report NP-4505-SR, " Manual of Recent Techniques-for LWR

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. Radiation-Field Control," (March 1986).

Licensee performance in controlling Unit I water chemistry was determined by interviews and discussions with chemistry, radiation protection, operations, maintenance, quality assurance, and plant engineering personnel; review of selected procedures, reports and records; and, observations of plant facilities'and equipment during tours of Unit 1.

Significant operating events related to impurity-intrusions, corrosion induced failures of plant equipment and other problems were reviewed for the period since commercial operation in 1974. The review assessed the licensee's program during restart in the areas of organization; procedures; and, self-identification /

correction of deficiencies, design / operation of water systems, sampling / measurement, and implementation of the program.

6.2 Organization Although there appeared to be a clear corporate commitment to and support for an effective water chemistry control program, the licensee was unable to provide a policy statement from GPU Nuclear supporting

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that commitment. Goals and objectives for the program were provided in two GPU Nuclear specifications; 1.e, SP 1101-28-001, " Primary Water Chemistry" and SP 1101-28-002, " Secondary Water Chemistry."

The organizational structure of the Unit I chemistry group was clearly defined. The group was composed of twenty chemistry tech-nicians, three supervisors, two chemists, and an engineer. The chemistry group reported to the manager of plant chemistry. The Unit I chemistry group authorities, responsibilities, and interfaces with plant and corporate organizations appeared to be clearly estab-lished and understood by the Unit I chemistry staff. Corporate chemistry roies were also clear; e.g.,

special analytical support for resin analysis, laboratory inter-comparison studies, and chemistry specifications.

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Unit I chemistry group staffing was reviewed with regard to routine operational and special restart analytical and sampling

responsibilities. No backlogs of samples or analyses were noted, indicating that adequate staffing had been provided to support restart. The licensee's chemistry technician training program had-received Institute for Nuclear Power Operations (INP0) accreditation and chemistry-technicians appeared to be fully knowledgeable of sampling and analytical methods used by the licensee.

6.3 Procedures

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SelectedplantprocedureswerereviewIdtodetermineif:

-critical chemical variables and limit / action levels for control

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of those variables had been identified; sampling schedules and locations for obtaining those samples had

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been provided; analytical methods and their bases had been identified;

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recording / trending of data and reporting requirements were

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provided; and, investigative and corrective actions to be taken when critical

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chemical variables exceeded their action levels were established.

The procedures reviewed were consistent with licensee conditions and technical specifications generally followed guidelines established by EPRI and the NSSS vendor and implemented specifications provided in the two SP's.

Maintenance procedures governing lapping and grinding activities on hard faced valve seats were reviewed to determine if the licensee had initiated control / cleanup procedures to minimize the ingress of cobalt-alloy debris. The licensee had modified valve maintenance procedures to include inflatable dams, lining the valve cavity with lint free cloth, wiping and vacuuming debris, and final cleanup with lint free cloth.

The licensee's procedures for monitoring the growth of out-of-core radiation fields were reviewed. Although the licensee conducts surveys of radiation fields in support of work activities under radiation protection procedures, the licensee does not have a standard radiation monitoring program to monitor the growth of radiation fields associated with transport of corrosion products, deposition on out-of-core surfaces of these corrosion products and long-term buildup of associated radiation fields from tFose corrosion products. The licensee is unable to systematically trend radiation field buildup since surveys taken in support of routine work rarely

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monitor radiation fields at set locations, which would allow such trending. This weakness was discussed with the licensee and will be

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reviewed in a subsequent inspection.

6.4 Self-Identification / Correction of Deficiencies Communication of chemistry data and trends to plant and corporate management was reviewed.

Chemical data and trends were presented to and discussed by plant management at daily staff meetings. Shift turnovers clearly disseminated information on water chemistry system-status. Corporate chemistry personnel met with plant chemistry personnel on a regular basis to discuss implementation of the chemistry control program.

The licensee identifies out-of-specification chemical parameters and suggests actions to correct those parameters with Chemistry Action Requests (CAR). The CAR are originated by the chemistry group, sent to operations, acted upon by operations, actions recorded, and com-pleted forms are returned to the chemistry group for review and record retention.

Bulk treatment chemicals; e.g., lithium hydroxide, hydrazine, hydrogen peroxide, cation, and anion resins, etc, were held in the licensee's warehouse until receipt inspections were completed to assure that those chemicals met specifications. Chemicals which were out of specification; e.g., incorrect concentrations, past expiration dates, etc., were evaluated and dispositioned in a formal review.

Pending that review, quality control holds prevented release of the bulk chemicals for plant use.

The licensee's quality assurance organization conducted surveillances at scheduled intervals to review adherence to procedures in chemistry.

In addition, audits of the chemical control program were completed by quality assurance personnel.

Review of licensee Audit S-TMI-86-17,

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" Chemistry Program," (September 29 - December 29,1986) showed that the audit examined technical specification compliance, organization, training / qualification of personnel, control of measurements and chemicals, and reviewed contracted services.

6.5 Design / Operation of Water Systems The licensee's primary, secondary, and auxiliary water systems were reviewed for familiarization with components and materials and to identify potential pathways for impurity ingress. Operating schemes for pH, lithium hydroxide, hydrazine, boration, and oxygen control were reviewed. Resin capacity management for the purification /

make-up and condensate polishing systems were reviewed and discussed with the licensee. The operating history of the plant systems was briefly reviewed to determine significant off-normal chemical behavio *~

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Within the scope of this review, the following items were noted,

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The ifcensee uses a make-up and purification system consisting-

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of two purification demineralizers to maintain primary system chemistry. A decreasing lithium with boron operating scheme is used.

The licensee has always used all volatile treatment (AVT) in the

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secondary system. A "Powdex System" (consisting of six filter demineralizers with_five in service /one in standby) is used to maintain feedwater. quality.

Resin bed replacements were con-ducted on high vessel differential pressures, high vessel. outlet conductivity and/or predetermined volume of processed water.

Primary system materials include stainless steel, inconel,

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zircaloy, and stellite providing a number of cobalt-bearing alloys for cobalt-58 and cobalt-60_ formation. The secondary system materials include stainless steel condenser tubes and carbon steel feedwater piping.

Reducible copper sources in the secondary system were not apparent, reducing the likelihood of copper promoted denting of steam generator tubes.

Condenser circulating water is fresh water from the Susquehanna

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River with cation conductivity measurements for condenser tube failure recognition. No evidence of extensive tube failures in the condenser was noted during restart.

Sulfur compounds introduced into the primary coolant promoted

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intergranular stress-assisted cracking of Once-Through Steam Generator (OTSG) tubing during 1981 hot functional testing.

Minimal fuel pin failures; i.e., estimated two pins of 36,816

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pins present in the core, were noted during restart.

Evidence of leakage from valves, pumps, and flanges in systems

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containing borated water were noted during plant tours which provided evidence of incipient _ seal failures in those systems before and during restart. Based on these inspections and tours, the licensee has established a program to affect necessary repairs.

Although evidence of air inleakage through the seals in conden-

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sate pump "A" was noted, dissolved oxygen levels in the feedwater were centro 11ed to abou; fifteen parts per billion (ppb) during restart.

Examination of turbine components during this outage showed no

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evidence of stress-corrosion cracking on turbine wheels and only minimal deposits on turbine blades. The licensee was analyzing the deposits in an off-site laboratory.

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' Cohtamination.was'found'in the turbine which-indicated primary-

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to-secondary leakage. Contamination: sufficient to require i

radiological control activities was noted.

Replacement resin testing by the licensee's resin laboratory

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provided good quality control of replacement resins'. Resin

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cleaning regeneration and/or replacement frequencies appeared F

adequate and responsive to small_ changes'in resin bed effluent quality which indicated close monitoring of resin performance.

6.6 Sampling / Measurement

.The. licensee's sampling and in-line instrumentation program was reviewed for conformance with licensee commitments and ASTM recom-mendations.

Sampling points and the primary and secondary chemistry

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sampling panels.were observed.

In-line. instrumentation sampling points and in-line. instrumentation appeared to be adequateoto monitor postulated impurity ingresses; e.g., condenser tube leaks, air inleakage of seals, and resin intrusions, and on the secondary side,.

in general, agreement with EPRI guidance.

Procedures for comparison of in-line instrumentation and laboratory instrumentation appeared to be informal and this observation was discussed with the licensee.

Although general corrosion samples were taken, correlations with activation of those materials were not routinely conducted and trended.

6. 7-Implementation Technical specification and license condition surveillance and pro-cedurally required sampling / analyses for January, May, and October 1986 were reviewed.

Trends of pH, dissolved oxygen, sulfate, chloride, and corrosion products for the restart period were reviewed and discussed with the-licensee.

Implementation of corrective actions related to chemistry for the following were reviewed:

Licensee Event Report (LER)79-011, dated April 5,1979, " Leaking

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Spent Fuel Pool Piping;"

LER 79-013, dated June 20,1979, " Crack in Suction Piping From

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Borated Water Storage Tank;"

LER 81-001, dated January 17, 1981, " Leaks-in Make-up and Puri-

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fication System Bypass;"

LER 81-003, dated November 25, 1981, " Primary to Secondary Tube

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Leakage in Both Once-Through Steam Generators;" and, LER 84-007, dated November 11, 1984, " Detective Once-Through

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Steam Generator Tubes."

Within the scope of this review, no violations were note ?Q c

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7.

Licensee Action on Previous Inspection Findings

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7.1 (Closed) Unresolved Item (289/86-06-06):

Nuclear Services Closed Cycle Cooling Water Hydrostatic Test

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The licensee identified that a section of piping of the nuclear services I

closed cycle cooling water system (NS) was not pressurized to the ASME Code required 110 percent of design pressure (150 psig) during a i

hydrostatic test. The hydrostatic test was performed to adhere to j

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the ten year testing cycle required by 10 CFR 50; therefore, the test I

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appeared not to qualify as a successful part of the inservice inspec-

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j tion plan.

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Licensee engineering personnel have redefined the design pressure for I

the NS piping involved (suction side of the NS pumps). Taking the l

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maximum pipe pressure as the NS pump's shutoff head (80 psi) plus an

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elevation head of approximately 15 psi, the new NS design pressure was evaluated to be 100 psig. The old NS design pressure was rated i

at 150 psig as indicated on system diagrams.

Since the hydrostatic pressure for the piping involved was 118 psig, the NS hydrostatic test passed the ASME Code requirement (110 psig) under the new design pressure.

Since the test pressure was approximately twice the normal

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i operating pressure (60 psig), there is no safety concern and this item is closed.

7.2 (Closed) NRC Temporary Instruction (289/25-00-13): Trial Use of Water Chemistry Insection Procedures.

This inspection (paragraph 6) documented the second in a series of inspections of the licensee's water chemistry control program and in-volved trial use of two NRC inspection procedures.

This item is closed.

7.3 (Closea) Unresolved Item (289/85-20-03):

Completion of Review of Design and Installation of Fuel Handling Building ESF Ventilation System.

This item was reviewed in Section 3 of this report and is closed.

7.4 Summary In summary, the licensee response to issues and unresolved items during this inspection period appeared to be timely and adequate for the circumstances addressed.

8.

Exit Interview The inspectors discussed the inspection scope and findings with the licensee management at a final exit interview conducted January 9, 1987.

Interim exits occurred on December 17, 1986, (ISI) and December 19, 1986, (radiological water chemistry).

Senior licensee personnel attending the final exit meeting included the following:

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J. Colitz, Plant Engineering Director, TMI-1 H. Hukill, Director, TMI-1

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S. Otto, TMI-1 Licensing

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'R Toole, Operations and Maintenance Director, TMI-1

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The inspection results as discussed at the meeting are summarized in the cover page of the inspection report.

Licensee representatives indicated that none of the subjects discussed contained proprietary or safeguards information.

Unresolved Items are matters about which information is required in order to ascertain whether they are acceptable, violations, or deviations.

Unresolved items discussed during the exit meeting are addressed in paragraphs 2.2.2, 4, 5.2, and 7.