IR 05000289/1990010

Insp Rept 50-289/90-10 on 900507-11.Violation Noted.Major Areas Inspected:Licensee Implementation of Reg Guide 1.97, Rev 3 Re post-accident Monitoring Instrumentation

ML20055D083
Person / Time
Site:	Three Mile Island
Issue date:	06/22/1990
From:	Anderson C, Cheung L, Paolino R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20055D081	List: IR 05000289/1990010 ML20055D080 ML20055D082
References
RTR-REGGD-01.097, RTR-REGGD-1.097 50-289-90-10, NUDOCS 9007030190
Download: ML20055D083 (12)

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-U, S. NUCLEAR REGULATORY COMMISSION

REGION I

l Report N /90-10 Docket N License No. DPR-50 1

'l Licensee: GPU Nuclear Corporation P. O. Box 480 Middletown, Pennsylvania 17057 Facility Name: Three Mile Island Unit 1-Inspection At:- Middletown, Pennsylvania Inspection Conducted: May 7-11', 1990 Inspectors: nar M_

L."Cheung, Senior Reactpr' Engineer, h

/date' t Plant SystemsSection V iB, DRS .

&&0SeniorReQyorEngineer, R.7. Paolin S' N

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Plant ys e s Section, EB, DRS Approved by: [ (, %S 0 C. J. f/nderson, Chief, Plant System date Section, Engineering Branch, DRS l Inspection Summary: Inspection of May 7-11,1990[InspectionReportN /90-10) i

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' Areas Inspected: Special, announced inspection to review the licensee's !

implementation of Regulatory Guide 1.97, Revision 3 which relates to post !

accident monitoring instrumentatio '

Results: Based on this inspection, the inspectors determined that the licensee had implemented a program to meet the recommendations of R.G. 1.9 _,

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One violation (wiring not meeting the separation criterion) and one unresolved item (instrumentation and power cables bundled together) were identifie .

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DETAILS

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1.0 Persons Contacte See Attachment 1 2.0 Background The purpose of this inspection was to revies instrumentation systems for assessing plant conditions during and follcwing the course of an accident ,

based on the criteria specified in Regulat9ry Guide (RG) 1.97, Revision )

3. These systems were inspected to deterrrine if they were installed in !

accordance with Generic Letter number 82-33 " Requirements for Emergency Response Capability" (Supplement I to NUREG-0737). This letter specifies those requirements regarding emergency response capabilities that have been approved by the NRC for implementation. This supplement also discusses, in part, the application of RG 1.97 to the emergency response facilities, including the control room, the technical support center '

(TSC) and the emergency response facility. Regulatory Guide 1.97 identifies the plant variables to be measured and the instrumentation !

criteria for assuring acceptable emergency response capability during and following the course of an acciden ;

Regulatory Guide 1.97 divides Post Accident Instrumentation into three categories and-five type The three design categories are noted as 1, 2 !

and 3. Category 1 has the most stringent design requirements and Category i 3 has the least stringen The five types of instrumentation identified s in the Regulatory Guide are types A, B, C, O and Type A variables are plant specific and classified by the licensee. Type B variables i provide information to indicate that plant safety functions are being ,

accomplished. Type C variables provide information regarding the breach !

of barriers for fission product. release. Type 0 variables indicate the l operation of individual safety systems. Type E variables are those that i indicate and determine the magnitude of the release of radioactive i materials. Each variable type can be any design category. However, !

Type A variables must meet Category 1 design requirement i

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3.0 Scope The NRC inspection scope included: equipment qualification (Seismic and Environmental), redundancy of power supplies, measured variables, display and recording methods used, independence and separation of electrical ;

circuits, range and overlapping features of multiple instrument indicators, equipment identification for RG 1.97 instruments, service, test and surveillance frequency, and direct and indirect measurement of 3 parameters of interes The safety related (Q) and EQ master equipment lists were reviewed for the instruments selected to ascertain whether they had been evaluated and tested to the appropriate environmental, quality assurance (QA) and seismic qualification requirement J

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4.0 -Inspection Details The inspectors held discussions with various members of the licensee's staff, reviewed drawings and procedures, and selected variables for a system walkdown. Walkdowns were performed for the sensing instruments (transmitters and 02 and H2 analyzers) at various locations of the auxiliary building and the display in'struments in the control room to assess the implementation of RG 1.97, Revision Instrument variables reviewed included neutron flux, reactor coolant system hot and cold leg temperatures, reactor coolant pressure, reactor coolant inventory, containment pressure, containment hydrogen concentration, high pressure safety injection system flow, refueling water storage tank level, steam generator level and pressure, and emergency feedwater flo Characteristics examined for each variable include identity, location, j function, separation (physical / electrical),-isolation, seismic qualifica- '

tion , power source' environmental qualification, and instrument range ,

The following instrumentation was examined: i l

4.1 Neutron Flux Monitor l

RG 1.97 indicates that the Neutron Flux is a Type B, Category 1 ,

variable. The following channels are provided to monitor this l'

variable:

Sensor Power Channel Indicator Recorder Range NI-YE-11- A NI-YI-11 Plant -8 10 to 100% Power :

Computer

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NI-YE-12 B NI-YI-12 10 to 100% power )

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The installed system provides signals from redundant out-of-core !

detectors to redundant wide-range indicators in the control roo The Class IE qualified instrumentation utilizes specifically designed '

cables to maintain sensitivity of the signal from the detectors to k the preamplifiers located outside the containment. Twisted shielded i pair cables connect the preamplifiers to the signal conditioning f cabinets. An electrically isolated signal, to the plant computer, i provides a wide range on-demand recording and display for one channel. Within the scope of this inspection no deficiencies were identifie .2 Reactor Coolant Cold Leg Water Temperature The licensee classified Reactor Coolant Cold Leg Water Temperature as a Type A, Category 1 variable. The following channels were provided to monitor this variabl ,

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Sensor Power Channel Indicator Recorder Range RC-TE-959 A RC-TI-959A Plant Computer 50-650 F RC-TE-961 B RC-TI-961A Plant Computer 50-650 F Regulatory Guide 1.97-recommends instrumentation with a range of 50-700 F for this variable. The licensee has provided qualified, redundant instrumentation with a range of 50-650'F. The. licensee considers the existing ranges (50-650 F) adequate based on maximum steam generator pressure of 1200 psig and a corresponding saturation temperature of 600 F. Therefore, the cold leg temperature =would ,

always be at or below the existing range value. (This is a B&W Owner's Group position). This devi a from Regulatory Guide 1.97 -

was addressed in the Safety Evaluatt .leport (SER) and was accepted by the NR On-demand recording capability is provided by the plant compute Within the scope of this inspection, no deficiencies were identifie .3 Reactor Coolant Hot Leg Water Temperature RG 1.97 indicates that the Reactor Coolant Hot Leg Water Temperature is a Type C. Category 1 variable. The following channels were provided to monitor this variable:

Sensor Power Channel Indicator Recorder Range RC-TE-958 A RC-TI-958A Plant Computer 120-920 F RC-TE-960 B RC-TI-960A Plant Computer 120-920 F Regulatory Guide 1.97 recommends instrumentation with a range of 50-700 F for this variable. The licensee is using a- 120-920'F range for.this variable. The basis for deviating from the Regulatory Guide 1.97 recommendation is that at temperatures less than 300 F the. plant is in the decay heat removal mode at cold shutdown and hot leg water temperature indication is not required. In addition, Category I core exit thermocouples provide information below 102 On-demand recording is provided by the plant computer for both channels. Within the scope of this inspection, no deficiencies were identifie ' Reactor Coolant Pressure The licensee classified Reactor Coolant Pressure as a Type A, Category 1 variable. The following channels have been provided to monitor this variable:

Sensor Power Channel Indicator Recorder Range RC-PT-949 B RC-PI-949A 0-3000 psig RC-PT-963 A Plant Computer 0-3000 psig

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i The Reactor Coolant Pressure Instrumentation receives its signal from i existing class IE qualified redundant pressure transmitters PT-949 '

and PT-963. The transmitters are connected via. class IE circuits to existing signal conditioning units in cabinets Al and B Existing -j pressure indicators PI-949 and PI-963 on the remote shutdown panel i and the control room pressure indicator PI-949A were modified to incorporate the new scale to measure a range of 0-3000 psig. This change does not affect the function or range of the saturation tem-perature monitor, however, with the expanded range the signal characterizer which provides an input to the saturation temperature monitor circuitry required recalibration to the new 0-3000 psig range. On-demand recording and display capability are provided by the j plant compute '

Within the scope of this inspection, no deficiencies were identifie .5 Reactor Coolant Inventory  ;

The Reactor Coolant Inventory instruments are classified as Type B -

variable, Category 1' instruments in RG 1.97. The licensee has provided the following instruments for post-accident monitoring of this variable:

Power Sensor Channel Indicator Recorder Range RC-LT-1035 A -

Plant Computer 0-180" RC-LT-1036 B -

Plant Computer 0-180" RC-LT-1033 A -

Plant Computer 0-590" RC-LT-1034 B -

Plant Computer 0-590"

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The instrument ranges provided cover the ranges recommended in RG 1.97. The first two transmitters are used to measure the reactor vessel level while the other two are provided to detect the voids in the hot leg piping " candy canes" of the steam generators. The variable legs of all of the four transmitters are connected to a common tap on the decay heat drain lin This deviation was addressed in the SER for NUREG 0737 item IIF2 and was previously accepted by the NR Density compensations from the reactor vessel temperature and the reference leg temperature are provided for all of the four instrument channels. No indicators or recorders are provided for these instruments. However, a computer input point is provided i for each of these instrument channels for display on the Safety Parameter Display System (SPDS) screen upon demand. Justification for this deviation was provided by the licensee in their submittal and was accepted by the NR ,

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All of the above instrument loops were found to be in calibration as evidenced by the calibration record The inspector reviewed the associated' drawings and procedure No deficiencies were identified. See Section 5.0 for the discussion of a lack of specific marking in the control room.-

4.6 Containment Pressure 7'

RG 1.97 indicates that Containment Pressure _is a Type B, Category 1 variabl The following channels are provided to monitor this variable:  !

Power Sensor Channel Indicator Recorder Range BS-PT-981A A BS-PR-981 Plant Computer 0-175 psig BS-PT-982A B BS-PR-982 Plant Computer 0-175 psig BS-PT-982B B BS-PR-982 Plant Computer -5 to +5 psig BS-PT-981B A BS-PR-981 Plant Computer -5 to +5 psig i

The installed instrumentation conforms with the recommendations provided in Regulatory Guide 1.97 for this variabl On-demand recording capability is provided by the plant i compute Within the scope of this inspection, no deficiencies were identifie .7 Containment Hydrogen Concentration The licensee classified the containment hydrogen concentration as a Type A variable. Accordingly, the licensee furnished Category 1 sampling, process and display instrumentation. The monitoring of 3 this variable is performed by the following redundant instrument channels:

Sensing Power Elements Divi sion Recorder Range wDG-AE-42A A WDG-AR-42A 0-10%

WDG-AE-42B B WDG-AR-42B 0-10%

The hydrogen concentration display instruments are located on the main control board. All instrument loops were found to be properly calibrated as evidenced by the calibration records. Within the scope of this review, no deficiencies were identifie See Section 5.0 for a discussion of a lack of specific identification of display instruments in the control roo .

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4.8 High Pressure Safety Injection System Flow The licensee classified high pressure safety injection flow as

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a Type A, Category 1. variable. The following four instrument channels were provided to monitor-this variable:

Power Sensor Channel Indicator Range MU-FT-1126 A MU-F1-1126 0-1200 gpm MU-FT-1128 B MU-FI-1128 0-1200 gpm MU-FT-1127 A MU-FI-1127 0-1200 gpm MU-FT-1129 B MU-FI-1129 0-1200 gpm The licensee's calculation determined that maximum flow for the flow element is 954,1 gpm. The range recommended in RG 1.97 is 0 to 110% of design flow. Therefore, the instrument range covers the recommended rang No recorder is provided for this variabl However, computer inputs are provided for on-demand display and recording. Redundant channels are electrically and physically separated. The transmitters were identified on the EQ master list and the instruments were determined to be in calibration. Within the scope of this review, no deficiencies were identifie .9 Borated Water Storage Tank Level (RWST)

The licensee classified the Borated Water Storage Tank Level as a Type A, Category 1 variable. The following channels are provided to monitor this variable:

Power Sensor Channel Indicator Recorder Range DH-LT-809 B DH-LI-809A Plant Computer 0-60 f DH-LT-808 A DH-LI-808A Plant Computer 0-60 f The BWST redundant level instrumentation consists of an existing Class IE transmitter (LT-809) and a newly installed transmitter (LT-808) in the RWST tunnel. New class 1E signal conditiosi.'g modules installed in cabinets A3 and B2 provide Class IE signals to new control room indicators and electrically isolated outputs to existing computer inputs and annunicator for low and high level alarms. On-demand recording capability is provided by the plant compute Within the scope of this inspection, no deficiencies were identifie . . . . ,

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4.10 Steam Generator Level The licensee classified reactor water level as a Type A variabl ~Accordingly, the licensee provided the following Category 1 instru-ments for post-accident monitoring for this variable:

Power Sensor Channel Indicator Range For Steam Generator "A" FW-LT-775 A FW-LI-775B 0-640" FW-LT-776 B FW-LI-7768 0-640" For Steam Generator "B" FW-LT-778 A FW-LI-778B 0-640" FW-LT-779 8 FW-LI-7798 0-640"

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Regulatory Guide 1.97 recommends the instrument range for this variable to be from the tube sheet to the separators. The steam generators at TMI Unit I are once-through design and as such the heat exchanger area would be described as from the bottom tube sheet to the top tube sheet. The instrument range provided c 2 vers this rang This deviation was addressed in the SER and was accepted by the NRC, No recorder or computer inputs were provided for this instrument range. Instead, the licensee provided a recorder for the " start-up" range (0-388"). 'The licensee provided justification for this deviation, stating that following a design basis accident, the range of interest is up to the aspirating port at 376" level. The start up range covers this range of interes This deviation was discussed in the SER and was accepted by the NRC. Prior to this inspection, the licensee made a plant modification and changed the start-up range recorder to computer inputs. The licensee completed the final draft in April 1990 to incorporate this change in their FSA Since continuous indications were provided for all four channels, and the plant computer can provide similar information as the recorder, the inspector considered this change acceptable. This decision was made following discussion with the NRC office of NR .11 Steam Generator Pressure The licensee classified the steam generator pressure as a Type A, Category 1 variable. The following instruments were provided for the post-accident monitoring of this variable:

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Sensor Channel Indicator Range l MS-PT-950 A MS-PI-950A 0-1200 psig l'

MS-PT-951 B MS-PI-951A 0-1200 psig-MS-PT-1180 B MS-PI-1180 0-1200 psig MS-PT-1184 A MS-PI-1184 0-1200 psig j The licensee provided computer inputs to account for the on-demand recording capabilit During this inspection, the inspector observed that Regulatory Guide 1.97 recommends the range of steam generator pressure to be from zero "

to 20*4 above the lowest safety valve setting.' The lowest safety valve setting for TMI-1 is 1040 psig, Therefore, the recommended i range is 0-1248 psig. The licensee's instruments do not cover this 1 rang The licensee did not identify this deviation in their submit-l tal to the NR During this inspection, the licensee provided a '

justification for the acceptability of the provided range for the

~ inspector's review, The justification was based on the result of a generic study by the B&W owners group. The justification indicated that the maximum post-accident steam generator pressure is always below 1200 psig. Similar justifications were provided by other utilities for other B&W plants (e.o., Crystal River 3, Davis Besse, ,

0conne 1, 2 & 3, etc.) and were accepted by the NR The licensee stated that they would make a formal submittal to the NRC to justify this deviatio .12 Auxiliary Feedwater Flow The licensee classified auxiliary feedwater flow as a Type A, Category 1 variable. The following instruments were provided to monitor this variable after an accident:

Power Sensor Channel Indicator Range EF-FT-799 C EF-FT-799 0-700 gpm EF-FT-782 B EF-FT-782 0-700 pgm EF-FT-788 8 EF-FT-788 0-700 pgm EF-FT-791 C EF-FT-791 0-700 pgm The inspector verified that the provided instrument range covers the recommended range in RG 1.9 Redundant instrument channels are physically and electrically separated. The licensee provided computer inputs for this variable to account for on-demand recording capability. The transmitters were on the EQ master list and the instrument loops were in calibration. Within the scope of this review, no deficiencies were identifie ,

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l 4.13 1 solation Devices Where a Category 1 signal is used as input to a non-category 1 l system, Regulatory Guide 1.97, Revision 3, specifies the use of isolation devices which are fully qualified for use in Category 1 circuit Circuits examined indicate that the Foxboro Spec 200 series and the Action Instrument Model 4300-107 are used in the post-accident mounting systems. The Foxboro Spec 200 series is used in the process instrumentation loops (Reactor Water Level, Raactor Coolant Pressure, etc.) and the Action Instrument 4300-107 is used in the Neutron Flux circuitr Environmental and seismic test results indicate that both isolation devices are qualified for use in plant protection systems. Environ-mental testing for the Action Instrument was performed by Gamma Metics at the Teledyne Aeronautical Environmental Test Laboratories and Seismic Testing was performed at Wyle Laboratories' Norco facility (Contract No. K6219). Foxboro test results were reported in Type Test / Report 00AAB44, Revision =Within the scope of this inspection, no deficiencies were identifie .0 Physical Inspection The inspector performed a physical inspection of display instruments

located in the control room, and local instruments located in various areas of the Reactor Building. For the display instruments (indicators and recorders) specified, the inspector verified instrument function, instrument range and identification of RG 1.97 instruments. For the

' local mounted instruments, the inspector verified instrument mounting and supports, separation of cable routing and instrument tubing for redundant ;

instrument channels. During the week of the inspection, the plant was in i operation. As a result, instruments located inside the reactor contain-ment were not inspecte The inspectors observed that the Category 1 instruments had not been I specifically ider.tified as recommended by RG 1.97 regarding equipment ;

identification. A review of the licenree' submittal to the NRC, dated '

June 5, 1986, indicated that this deviation had been identified by the licensee in Table 1A, Item 9. The l icensee provided justification for 4 this deviation, stating that the 1;censee had conducted a human factor review and a control room desicr. review in 1980. Based on the result of those reviews, the licensee decided not to provide specific identification for RG 1.97 instrument in the control roo During the control room inspection, the inspector observed that the 120V power cables for the redundant containment high Range Radiation Monitors 1 did not meet the separation criteria specified in the licensee's procedure for the " Installation of Electrical Equipment," SP-1101-41-003, Revision *

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Section 4.4.3. Item C of this procedure states, in part, that: "six (6)

inch minimum free air sraces shall be maintained between redundant wiring and between Nuclear Safety Related (NSR) and non-NSR wiring from the raceway entrance to the termination points." The redundant 120V power cables were tied together within the PRF cabinet. This item is a violation of 10 CFR 50, Appendix B, Criterion V which states, in part, that: " Activities affecting quality shall be prescribed by documented instructions and accomplished in accordance with these instructions..." (289/90-10-01).

Panel PLF which contained the Steam Generator Pressure and Level Instru-mentation was also examined. The inspector noted that cables from the redundant steam generator level and pressure indicators were bundled together with other instrument power / signal cabling in the PLF cabine However, the cable from the steam generator pressure and level was wrapped with qualified insulating tape which acts as the fire barrier. The signal cable in the cable bundle was identified as unshielded cable. The inspector (

raised a concero regarding electro-magnetic interference from the commonly wrapped power cable with the analog signa This item is unresolved pending NRC review of licensee evaluation and justification regarding acceptability of the existing cable configuration ;

(289/90-10-02).

6.0 Surveillance Testing and Calibration The surveillance tests and calibrations of all RG 1.97, Category 1 instruments are performed by the Instrumentation and Control maintenance departmen The licensee employs a computerized data base for scheduling and tracking instrument calibration. The inspectors reviewed the data base for the instruments inspected, the frequency of calibration, and the calibration expiration date. The inspector conducted a review to deter-mine that procedures are in place for the performance of the calibratio No deficiencies were identifie .0 Unresolved Items Unresolved items are matters about which more information or further NRC review of licensee information is required in order to determine if they are acceptable items or violation An unresolved item identified during this inspection is discussed in Details, Paragraph 5.0 of this repor .0 Exit Meeting The inspectors met with licensee representatives (denoted in Attachment 1)

at the conclusion of the inspection on May 11, 1990 at the plant sit The inspectors summarized the scope of the inspection, the inspection findings and confirmed with the licensee that the documents reviewed by the team did not contain any proprietary information. The licensee agreed that the inspection report may be placed in the Public Document Room without prior licensee review for proprietary informatio At no time during this inspection was writter material given to the license l.s # ^ + t i k '

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- ATTACHMENT 1- ,

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[ LPersons Contacted '

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[A) - Genera,1 Public Utilities- Nuclear Corporation t

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A. Agarwal.: Instrumentation Manager _ 1

. G Bond, Director,-System Engineering i

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D.LDistel, Senior. Licensing Engineer

• W. Drendal,-Instrumentation Engineer i

• K. Eibon, Engineer', EP&I-

• R. Harding, Manager, QualityfClass/Engin. Confi .

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D. Hull, Plant Engineering .

.R. Knight, Licensed Engineer

• J. Kink, Engineer, Safety Analysis & Plant Control

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J.. Mancinelli,- Manager, Environmental. Qualification R. McGuey,- Manager,' . PWR Licensing 3 *Y. Nagai, BWR Licensing

• J..Roumes, Engineer, EP&I

, J.fSadauskas, Manager,EP&I D. Selar' Director, E&D;

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C. Smyth, Licensing

• J. Sullivan, Jr. , Director, Licensing B). United-States Nuclear Regulatory Commission

• S. Young, Senior Resident In'spector s

Note: * Denotes those present. at the' exit meeting :on' May;11,;1990.:

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