IR 05000289/1998002
| ML20249C436 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/22/1998 |
| From: | Marilyn Evans NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20249C433 | List: |
| References | |
| 50-289-98-02, 50-289-98-2, NUDOCS 9806290338 | |
| Download: ML20249C436 (18) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No.
50-289 License No.
DPR-50 Report No.
98-02 Licensee:
GPU Nuclear Corporation Facility:
Three Mile Island Station, Unit 1 Location:
P.O. Box 480 Middletown, PA 17057 Dates:
March 22 through May 23,1998 Inspectors:
Wayne L. Schmidt, Senior Resident inspector Samuel L. Hansell, Resident inspector Joseph E. Carrasco, Acting Resident inspector Approved by:
Michele G. Evans, Chief Reactor Projects Branch No. 7 Division of Reactor Projects l
9906290338 980622 PDR A00CK 05000289
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EXECUTIVE SUMMARY Three Mile Island Nuclear Power Station Report No. 50-289/98-02 This inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a nine week period of resident inspection.
Plant Operations GPUN operated TMI-1 safely over the period. Operators controlled the plant well, including performance of the power maneuvers to allow condenser work.
Control room discussions on the risk of maintenance items including the emergency diesel generator (EDG) overhauls and the combined outage on the "A" trains of the decay heat removal (DR), decay heat river (DH), and reactor building spray (BS) systems were good.
The annunciator panels generally reflected a " blackboard," and operators understood the reasons for annunciated conditions and used alarm response procedures.
Appropriate actions to monitor secondary chemistry parameters and to identify and correct condenser tube leakage showed a continued commitment by GPUN management to good secondary chemistry controls.
The design basis for both the normal and engineered safety feature (ESF) fuel handling building (FHB) ventilation systems were adequately discussed in the Updated Final Safety Analysis Report (UFSAR). GPUN maintained the ESF system in adequate condition and seismic qualification to support refueling.
While all Technical Specification (TS) required testing had been accomplished on the FHB ESF system, the routine testing did not verify that the system could maintain a negative pressure on the FHB following a design basis fuel handling accident, and did not include verification of satisfactory operation of the FHB environmental enclosure. GPUN had identified these deficiencies as part of their maintenance rule scoping review. The inspectors considered this an Unresolved item, pending review of initial ESF system installation testing and GPUN documentr. tion of the maintenance rule implementation issues. (Open - URI 98-07.-01)
The operations department management took good actions to enhance the understanding of expectations on operator procedure usage and senior operator operability l
determinations.
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GPUN management properly responded to a concern documented in Inspection Report 98-01 about the adequacy of licensee event report (LER) 98-002-00. Specifically the initial l
report did not include broad corrective actions to preclude a further missed spent fuel pool l.
water sample. Revision 01 to the LER adequately addressed the broader root causes.
'GPUN properly identified, reported (LER 98-004-00),and took corrective actions following a situation where both trains of the reactor building spray system were unavailable due to ii i
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a problern with a control room push-button for one train while the other train was removed froin service for surveillance testing. (Closed - NCV 98-02-02)
Maintenarigg GPUN performed the mechanical and electrical maintenance activities for the inspection and overhaul of the EDGs in accordance with approved procedures. NDE activities associated with the maintenance and overhaul of the EDGs were conducted by a certified Level 11 NDE engineer. GPUN met the regulatory requirements of TS pertinent to EDGs inspection and overhaul.
I GPUN took adequate corrective actions to allow closure of a previously open violad n on failure to have a preventive maintenance program for molded case circuit breakers for the fuel handling ESF ventilation. (Closed - eel 97-070 item 07014)
Enaineerina The engineering department supported safe plant operation through involvement in daily meetings and activities and in support of system outage activities. Of particular note, system engineers provided excellent support to the EDG and DH, DR and RB system outages.
The NRC staff and GPUN discussed the makeup system suction configuration, after GPUN identified that it was different than as stated in an NRC generic safety evaluation for B&W plants. Specifically, the suction cross-tie valves at TMl are open, although the NRC evaluation stated that they were shut. The NRC staff remained concerned that the opening of the cross ties would allow the third pump to potentially be affected by an unknown I
makeup tank low level condition. The inspector considered this an inspector follow item, pending additional review. (Open -IFl 98-02-03)
Plant SuDDod The inspector conducted plant tours during the period and did not identify any significant negative housekeeping or radiological control issues.
A previous Non-Cited Violation documented in Inspection Report 97-01 dealing with GPUN's failure to meet the requirements of 10 CFR 70.24, Criticality Accident Requirements, or to have an NRC approved exemption to the requirement was withdrawn.
The NRC has reconsidered this violation and concluded that, although a violation did exist, it was appropriate to exercise enforcement discretion. (Closed - Enforcement Discretion -
EA 98-112)
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TABLE OF CONTENTS EX ECUTIV E S U M M A RY.............................................. ii TA B LE O F C O NT ENT S.............................................. iv 1. Operations
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Conduct of Operations.................................... 1 01.1 G eneral Comments.................................. 1
Operational Status of Facilities and Equipment................... 1 02.1 Engineered Safety Feature System Walkdown-Fuel Handling Building Ventilation System s................................. 1
Operator Knowledge and Performance......................... 4 04.1 Operations Actions to Strengthen Responsibilities............ 4
Miscellaneous Operations issues............................. 4 08.1 (Closed) LERs 98-002-00 and 98-002-01.................. 4 08.2 (Closed) LER 9 8 -0 0 4-0 0.............................. 5 11. M a i nt e n a n c e................................................... 6 M1 Conduct of Maintenance................................... 6 M 1.1 G eneral Comm e nts.................................. 6 M1.2 Emergency Diesel Generator Annua! Overhaul............... 7 M8 Miscellaneous Maintenance issues............................ 8 M8.1 (Closed) eel 97-070 ltem 07014........................ 8 lli. Engine e ring................................................... 9 l
E1 Conduct of Engineering.................................... 9 j
E2 Engineering Support of Facilities and Equipment.................. 9 j
E2.1 Makeup System Suction Alignment issues................. 9 IV. Plant Support
................................................10 R1 Radiological Protecticn and Chemistry (RP&C) Controls............
P8 Miscellaneous EP issues..................................
P8.1 (Closed) Non-Cited Violation: Criticality Accident Requirements (EA 98-112)........................................10 l
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Man a geme nt M eeting s..........................................
X1 Exit M eeting Summ ary...................................
I INSPECTION PROCEDURES USED.....................................
ITEMS OPENED, CLOSED, AND DISCUSSED..............................
LI ST O F ACRO NYM S U S ED..........................................
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- Report Details Summary of Plant Status Unit 1 remained at 100% power throughout the inspection period, except for two periods of several days when GPUN lowered power to approximately 50% to allow repairs to condenser tube leakage, l. Operations
Conduct of Operations (71707,40500,92901)'
01.1 General Comments Operators controlled the plant well, including performance of power maneuvers to allow condenser work. The inspectors observed good control room discussions on the risk of maintenance items including the emergency aiesel generator (EDG)
overhauls and the combined outage on the "A" trains of the decay heat removal (DH), decay heat river (DR) and reactor building spray (BS) systems. The annunciator panels generally reflected a " blackboard," and operators understood the reasons foc annunciated conditions and used alarm response procedures.
Appropriate actions to monitor secondary chemistry parameters and to identify and correct condenser tube leakaga showed a contir.oed commitment by GPUN management to good secondary chemistry controls.
O2 Operational Status of Facilities and Equipment O2.1 Enaineered Safety Feature System Walkdown-Fuel Handlino Buildina Ventilation
. Systems a.
Insoection Scope The inspectors reviewed the design basis as documented in the updated final safety analysis report (UFSAR) and the technical specifications (TS) for the fuel handling building (FHB) ventilation systems, which included the FHB normal ventilation system (FHBNV) and the FHB engineered safety feature ventilation systems (FHBESF), and the assocbted radiation monitor. The inspectors then walked down the accessible portions of thc systems to verify installation and operation in accordance with the design basis. Tho inspection included a review of the FHBESF ventilation procedures, pipe and instrument drawings (P&lDs), and engineering documentation associated with system changes.
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' Topical headings such as 01, M8, etc., are used in accordance with the NRC standardized reactor inspection report outline. Individual reports are not expected to address all outline topic.
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Observations and Findinas The design of both FHBNV and FHBESF ensure a FHB negative pressure with respect to the outside, to preclude the unmonitored release of radioactive material to the environment. In addition, the safety-related FHBESF maintains a negative pressure on the fuel handling floor, limiting the release of radioactive materials to within 10 CFR Part 100 limits, in the event of a design basis fuel handling accident, discussed in UFSAR Chapter 14.
During FHBNV operation, control dampers in the supply and the exhaust ducts throttle to maintain a negative pressure in the FHB operating floor and truck bay.
Both dampers respond together to maintain supply air flow less than exhaust air flow, resulting in building pressure less than the outside pressure. Prior to beginning refueling operations, the operators place FHBESF in service, in parallel with the FHBNV. In the event of a DBA fuel handling accident the radiation monitor on the auxiliary fuel handling bridge or an air monitor in the FHBNVS exhaust would alarm and isolate the FHBNV from the FHB. In addition, operators at Unit 2 would be contacted by the Unit 1 control room to isolate the normal ventilation system at that unit because they share a common refueling floor.
The inspectors walked down both trains of the FHBESF, located on the roof of the Auxiliary Building in a seismically qualified enclosure. The inspectors found:
Structurally sound filtration units, fans, and air ducts.
- Accessible valves in the main system flow path in correct positions based on
visual observation of the stem positions.
- Operator aid plaques posted as described in the operating procedures.
- The inspectors reviewed system design parameters finding:
Up to date FHB parameters, procedures, and design bases information j
contained in the UFSAR.
The system engineer had submitted document change requests to support
the April 1998 UFSAR update, which resulted in a more clearly defined design basis. A detailed 50.59 safety evaluation was written to document the bases for the UFSAR changes.
With respect to FHBESF surveillance testing the inspectors found:
Procedures existed to perform all of the TS test requirements.
- Routine test procedures did not exist to ensure that the system met its
design basis of maintaining a negative pressure within the FHB following a i
fuel handling accident. Further, the system was not tested in the alignment that would automatically result if a fuel handling accident occurred (i.e., the
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FHBNV isolated as designed due to a high radiation signal on the auxiliary refueling bridge or in the normal exhaust duct). As such, testing did not demonstrate the ability of the FHBESF or the FHB environmental barrier, which according to UFSAR Chapter 14, " is included to limit potential leakage paths and isolate Unit 1 refueling floor from the Auxiliary Building."
The inspectors also noted a lack of the instrumentation for monitoring the
negative pressure in the FHB if generated by the FHBESF.
GPUN acknowledged the lack of surveillance procedures to ensure the
operation of the system to meet its design basis function and had identified these weaknesses during a recent maintenance rule evaluation. The inspectors and the system engineer discussed the inability to measure negative pressure in the FHB. To address the issues, GPUN planned to develop a surveillance test to test the FHBESF in its design basis configuration and to measure and record the Auxiliary and FHB negative pressure and to upgrade the current Auxiliary and FHB differential pressure control gages to include a negative pressure indicator.
Because FHBESF was only required during refueling, these deficiencies did
not represent a current operability issue, but will need to be resolved prior to the next refueling outage.
The inspectors also noted that the FHBNV negative pressure monitoring was imprecise, located on a local damper control gage board. GPUN had also identified this deficiency during the maintenance rule review and planned to upgrade the instrumentation and to conduct testing to verify the ability of the system to maintain a negative pressure. In the interim, the Auxiliary and Fuel Handling Building exhaust flowrate is monitored in the main control room. The exhaust flow i
is recorded every day and verified to be above the TS minimurn flow of 100,500 standard cubic feet per minute.
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Conclusions
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l The UFSAR adequately discussed the design basis for the FHBNV and FHBESF.
I Walkdown of the FHBESFindicated adequate system condition and seismic qualification.
While all TS required testing was accomplished on the FHBESF, the inspectors noted several deficiencies in the routine verifications of system operability.
Specifically, the routine testing did not verify that the system could maintain a negative pressure on the FHB following a design basis fuel handling accident, and
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did not include verification of satisfactory operation of the FHB environmental
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enclosure. Further, the FHB design did not incorporate any negative pressure
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monitoring instrumentation to indicate the negative pressure following isolation of J
the building from the normal ventilation system following a design basis fuel handling accident. GPUN commented that they too had identified these deficiencies during a maintenance rule implementation review. The inspectors considered this l
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potential violation of 10 CFR 50, Appendix B, Criterion XI, Test Controls an Unresolved item, pending review of initial FHBESF installation testing and GPUN documentation of the maintenance rule implementation issues. (URI 98-02-01)
Operator Knowledge and Performance 04.1 Operations Actions to Strenathen Responsibilities Operations department management took actions to issue expectations and
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operating guidelines to the department as a result of 1) the reactor vessel overfill during the Fall 1997 outage and 2) the lack of a proper operability determination when several fire dampers, designed to isolate the FHB in the event of an airplane crash, would not have been able to perform their intended functions. GPUN submitted licensee event report (LER) 98-005-00 on the fire damper issue. This LER l
and the associated corrective actions will be reviewed in a subsequent report.
l Specifically this new operations guidance covered:
Procedure use and compliance - this guidance made it clear that operators
are required to follow procedures whether the procedure needed to be in hand or, as applicable, when an operator relied on knowledge and learned ability.
Operability determinations - the guidance clarified the shift supervisor's
responsibilities with respect to determining operability and was consistent with the guidance in Generic Letter (GL) 91-18.
The insp'<: tors concluded that operations department management took good actions te chance the understanding of expectations on operator procedure usage and senior operator operability determinations.
Miscellaneous Operations issues 08.1 (Closed) LERs 98-002-00 and 98-002-01: " Missed Soent Fuel Pool Samole Followina a Water Addition."
a.
Inspection Scope (92700)
Following GPUN identification of a missed spent fuel pool (SFP) TS sampling requirement, the inspectors independently reviewed the TS, operating procedure, corrective action process (CAP) documentation, and the associated LERs. In addition, the inspectors observed the plant review group (PRG) meeting that discussed the revision to the original LER.
b.
Observations and Findinas NRC Inspection Report (IR) 50-289/98-01 documented the inspectors' review and determination that the original LER root cause was narrowly focused and did not consider the broader issue of the control personnel's responsibilities to ensure the l
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j completion of TS requirements. Senior GPUN management reviewed the initial LER and questioned the limited corrective actions, in response to feedback on the initial LER, the PRG met on March 20,1998, to review and discuss a revision to the original LER. At that meeting, the PRG discussion included additional corrective actions to address the control room staff's responsibility to ensure the performance of non-routine TS sample requirements.
The revised LER resulted in a document that contained a more comprehensive description of the issue and broad based corrective actions. The corrective actions included the addition of TS surveillance training to licensed operator requalification training.
c.
Conclusions Revision 01 to LER 98-002-00," Missed Spent Fuel Pool Sample Following a Water Addition," resulted in a more thorough root cause analysis determination and comprehensive corrective actions. The revised LER addressed the broader issue of control room personnel's understanding and control over TS sample requirements.
Therefore, the inspecters closed LERs 50-289/98-002-00and 98-002-01.
08.2 (Closed) LER 98-004-00. " Reactor Buildina Sorav Inocerable due to Control Room Switch Deficiencv" a.
Inspection Segp.e On February 18,1998, both trains of BS system were rendered inoperable when a pump discharge valve console push-button switch stuck in the " closed" position on the "B" train, and the "A" train was removed from service for surveillance testing.
The operators identified the condition after five hours. The inspectors conducted in-office and in-plant reviews of the associated root cause, and corrective and preventive actions following this issue, b.
Observations and Findinas The inspectors walked down the control room panels to note the physical location of switch BS-V-1B (BS pump motor operated discharge valve) on the panels. The inspector verified that the licensee replaced the defective "CLOSE" push-button switch with a new assembly. The failed switch was in the control room and was being used as a training visual aid. While in the control room, the inspectors examined the electrical drawings associated with the switch and received a brief explanation of the associated electrical circuitry.
The root cause of this event was improper assembly of the switch push-button.
The inspectors interviewed the operations director and the responsible operations engineer involved in the root cause determination, and reviewed the implementation of the corrective and preventive actions.
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There were no adverse consequences due to this event, since the BS system did not need to automatically respond to a design basis event. Further operator action could have been taken to return the "A" BS system to an operable status, since it was in the process of surveillance testing.
The inspectors verified that the licensee properly notified the NRC via the l
emergeny r. notification system telephone in accordance with 10CFR50.72 and via l
LER 98-004-00in accorder.ce with 10CFR 50.73.
The inspectors verified that the operations department implemented formal training to familiarize operations personnel with the details of the inoperable push-button.
The inspectors found the training handout concise and clear, with an illustration to enable personnel to visualize the complete push-button assembly. The licensee also added a requirement for operators to visually observe / verify switch position following operation, c.
Conclusion The licensee identified the unavailability of the RB spray system and took good action to correct the problem with the control switch push-button. This non-repetitive, licensee identified and corrected violation of TS is being treated as a Non-Cited Violation, consistent with Section Vll.B.1. of the NRC Enforcement Policy.
(NCV 98-02-02).
II. Maintenance M1 Conduct of Maintenance (62707,61726,92902)
M 1.1 General Comments The inspectors observed activities in planning and performance of the May 1998 'A'
decay heat removal iDH), decay heat river (DR), and reactor building spray (RB)
system outagc. The inspectors found that GPUN adequately scheduled and conducted the outage. The risk plan associated with the outage was well understood and management focus was appropriate to complete the work within the prescribed schedule time of 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br />, well within the TS allowable outage time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Observation of work activities in the screenhouse showed good use of procedures and supervisory involvement.
The maintenance department appropriately conducted activities on the DH, DR, and BS systems. Daily plant and maintenance meetings before and during the outages demonstrated good management support and pre-planning work. Work packages were well prepared and procedures properly used by technicians in all observed cases.
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7 M1.2 Emeraency Diesel Generator Annual Overhaul a.
Insoection Scop _q The inspectors observed all or portions of the following maintenance and surveillance work activities: GPUN's implementation of selected mechanical, electrical and metallurgical mairdonance activities of the inspection and overhaul of both EDGs.
b.
Observations and Findinos The inspectors observed different phases of the maintenance and overhaul of the EDGs with the following highlights:
GPUN properly utilized and managed the vendor representative.
- Continuous quality verification support was evident during the outage and
provided good oversight.
The mechanical maintenance department conducted their activities in
accordance with Surveillance Procedure 1301-8.2, revision 68, " Diesel Generator Major inspection (Mechanical)." The inspectors observed good procedure usage during initial machine disassembly including exhaust header ring collector inspections. Further, GPUN implemented vendor recommendations on limiting lower crankshaft strain and inspection of the
- 14 bearing on both EDGs. Both #14 bearings were replaced, although, neither had failed, both showed some signs of raised bearing metal at the lower center!ine. Additionally, in order to accommodate the vendor's recommendation on lower crankshaft strain, maintenance mechanics needed to move both generators.
The electrical maintenance department efficiently collected vibration data on
the engine, generator, and vertical cooling fan drive. During the post-overhaul testing of the 'B' EDG while the EDG was running at a speed of 900 rpm no voltage indication registered in the control room. Electrical maintenance and engineering personnel effectively and efficiently polished all connection points on the potential transformers (PT's), and extending the door arm operating mechanism to apply additional tension to the spring to ensure proper contact. Upon completing these repairs, operators satisfactorily performed the pertinent post-repair test.
The inspectors observed nondestructive examination (NDE) activities,
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examination (penetrant liquid and visual examination) performed for the i
cooling f an blades of 'A' and 'B' EDGs. The indications observed on the fan l
blades were characterized as casting surface indications and not service
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induced. The indications were short, narrow, and superficial (based on the amount of a penetrant bleed out) linear indications and were satisfactorily i
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dispositioned. The inspectors concluded that the NDE activities associated i
with the maintenance and overhaul of the EDGs were conducted effectively
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by a certified Level 11 NDE engineer.
GPUN met TS Section 4.6.1.c requirements to conduct an annual EDG outage in accordance with the manuf acturer's recommendations for this class of standby service. Further, the inspectors verified that GPUN completed the inspection and overhaul activities for the two EDGs in the prescribed time stated in Technical Specifications Section 3.7.2 c.
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Conclusion GPUN performed the mechanical and electrical maintenance activities for the inspection and overhaul of the EDGs in accordance with approved procedures. NDE activities associated with the maintenance and overhaul of the EDGs were conducted by a certified Level ll NDE engineer. GPUN met the regulatory requirements of TS pertinent to EDGs inspection and overhaul.
M8 Miscellaneous Maintenance issues M8.1 (Closed) eel 97-070ltem 07014:Testina of Molded Case Circuit Breakers a.
Backaround (92902)
NRC Inspection Report 96-201, dated April 15,1997, addressed the original molded case circuit breaker testing issue as an Unresolved Itam (URI 96-201-20). NRC issued the design inspection team enforcement letter on October 8,1997, to document the electrical circuit breaker issue as a violation (eel No.97-070 ltem 07014). Immediate and long term corrective actions were scheduled to be completed by July 31,1997.
The Institute of Electrical and Electronics Engineers (IEEE) standard, Section 6.3, requires that electrical system components that are not exercised during normal operation be demonstrated to be operable, and specific tests and frequency be included in the maintenance program. GPUN's GMS-2 database specifies the testing frequency for molded case circuit breakers. The NRC design team identified that molded case circuit breakers in MCCs 1 A ES ESF VENT and 18 ES ESF VENT had not been tested since their installation in 1986. In 1993, GPUN added these breakers to GMS-2 and scheduled the tests for 1997 and 1998. The scheduled I
date for the circuit breaker testing was within the allowed four year maintenance cycle.
b.
Insoection Scope The inspectors reviewed the GPUN notice of violation response and associated corrective actions including corrective action program (CAP) report T1997-OOO6, I
the electrical breaker maintenance job orders (JOs), preventive maintenance (PM)
tasks added to the general maintenance system (GMS-2) computer database, and l
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the GPUN audit of the nuclear safety related motor control center (MCC) breaker PM tasks. The inspectors verified tne breaker documentation in the plant and reviewed related documentation in the office.
c.
Observations and Findinas GPUN completed thorough and satisfactory corrective actions associated with the molded case circuit breakers in the FHBESF ventilation system. The breaker PM tasks were added to the GMS-2 computer data base and the three PM tasks were completed satisf actorily by June 14,1997. The JO documentation for the three breakers included in JO Nos. 135852,131353, and 131352, was completed as required. The next GMS-2 breaker PMs were scheduled for March 2001,to meet the four year test frequency. GPUN completed an audit of the nuclear safety related MCC breaker PM tasks on June 1,1997, which did not reveal, any addition breaker PM problems.
d.
Conclusions The GPUN response and corrective actions associated with the molded case circuit breaker preventive maintenance (PM) tasks for the ESF ventilation system were thorough and completed satisfactorily. The breaker PM tasks were added to the general maintenance system (GMS-2) computer data base and the three PM tasks were completed satisfactorily by June 14,1997. The inspectors closed eel 97-070 item 07014.
111. Enaineerina E1 Conduct of Engineering (37551,92903)
The engineering department supported safe plant operation through involvement in daily meetings and activities and in support of system outage activities. Of particular note, system engineers provided excellent support to the EDG and DH/RB system outages.
E2 Engineering Support of Facilities and Equipment E2.1 Makeun System Suction Alianment issues a.
Insoection Scop _e During the fall 1997 refueling outage, GPUN changed the normal position of the makeup (MU) pump suction cross tie valves frorn normally shut to normal open, to address severai::ystem operation concerns. GPUN completed this modification using 10CFR 50.59 and documented the basis in a safety analysis dated August 18,1997.
Following the outage the system engineer noted that an NRC safety evaluation dealing with a potential generic B&W common mode failure of the MU pumps, L.
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dated November 14,1997, stated that GPUN operated with the suction cross tie valves closed. The system engineer brought this discrepancy to the attention of the resident inspectors. The resident inspectors contacted the NRR project manager to discuss the issue.
b.
Observations and Findinas On May 14,1998, the NRR staff, the resident inspectors, and GPUN personnel discussed the configuration of the MU system following the modification.
Specifically, the system engineer identified several differences between TMI and the Oconee plant where a problem occurred, that allowed two MU pumps to be damaged. These differences include:
Makeup tank (MUT) level instruments with dry reference legs. At Oconee,
unknown draining of wet reference legs led to indicated level being higher than actual and damage to two MU pumps.
No automatic low MU pump discharge header auto start of the second pump.
- At Oconee, when the first pump lost discharge head, the second pump automatical!y started, leading to its damage.
GPUN also pointed out that the MUT level and pressure was controlled within a tight analyzed band to ensure adequate water supply and net positive suction head (NPSH) to the MU pumps in the event of a loss of coolant accident (LOCA).
c.
Conclusion
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The NRC staff remained concerned that the opening of the cross ties would allow the third pump to potentially be affected by an unknown MUT low level condition.
The inspector considered this an inspector follow item, pending additional review.
(IFl 98-02-03)
IV. Plant SuDDort R1 Radiological Frotection and Chemistry (RP&C) Controls (71750)
The inspector conducted plant tours during the period and did not identify any significant negative housekeeping or radiological control issues.
P8 Miscellaneous EP lasues (92904)
P8.1 (Closed) Non-Cited Violation: Criticality Accident Requirements (EA 98-112)
a.
Inspection Scope This refers to the inspection at Three Mile Island Units 1 and 2 described in Inspection Report Nos. 50 289/97-01 and 50-320/97-01, issued on March 20, 1997. As a result of that inspection, a Non-Cited Violation was assigned for the
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the GPUN audit of the nuclear safety related motor control center (MCC) breaker PM l
tasks. The inspectors verified the breaker documentation in the plant and reviewed
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related documentation in the office.
c.
Observations and Findinas GPUN completed thorough and satisfactory corrective actions associated with the molded case circuit breakers in the FHBESF ventilation system. The breaker PM tasks were added to the GMS-2 computer data base and the three PM tasks were completed satisfactorily by June 14,1997. The JO documentation for the three breakers included in JO Nos. 135852,131353, and 131352, was completed as l
required. The next GMS-2 breaker PMs were scheduled for March 2001,to meet the four year test frequency. GPUN completed an audit of the nuclear safety I
related MCC breaker PM tasks on June 1,1997, which did not reveal, any addition breaker PM problems.
d.
Conclusions The GPUN response and corrective actions associated with the molded case circuit -
breaker preventive maintenance (PM) tasks for the ESF ventilation system were thorough and completed satisfactorily. The breaker PM tasks were added to the general maintenance system (GMS-2) computer data base and the three PM tasks were completed satisf:ctority by June 14,1997. The inspectors closed eel 97-070 Itam 07014.
Ili. Enaineerina E1 Conduct of Engineering (37551,92903)
The engineering department supported safe plant operation through involvement in daily meetings and activities and in support of system outage activities. Of particular note, system engineers provided excellent support to the EDG and DH/RB system outages.
E2 Engineering Support of Facilities and Equipment j
l E2.1 klakeuo System Suction Alianment issues a.
insoection Scong
During the fall 1997 refueling outage, GPUN changed the normal position of the makeup (MU) pump suction cross tie valves from normally shut to normal open, to address several system operation concerns. GPUN completed this modification using 10CR 50.59 ond documented the basis in a safety analysis dated August 18,1997.
Following the outage the system engineer noted that an NRC safety evaluation dealing with a potential generic B&W common mode failure of the MU pumps,
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dated November 14,1997, stated that GPUN operated with the suction cross tie valves closed. The system engineer brought this discrepancy to the attention of the resident inspectors. The resident inspectors contacted the NRR project manager to discuss the issue, b.
Observations and Findinas On May 14,1998, the NRR staff, the resident inspectors, and GPUN personnel discussed the configuration of the MU system following the modification.
Specifically, the system engineer identified several differences between TMl and the Oconee plant where a problem occurred, that allowed two MU pumps to be damaged. These differences include:
Makeup tank (MUT) level instruments with dry reference legs. At Oconee, l
unknown draining of wet reference legs led to indicated level being higher
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than actual and damage to two MU pumps.
No automatic low MU pump discharge header auto start of the second pump.
- At Oconee, when the first pump lost discharge head, the second pump automatically started, leading to its damage.
GPUN also pointed out that the MUT level and pressure was controlled within a tight analyzed band to ensure adequate water supply and net positive suction head (NPSH) to the MU pumps in the event of a loss of coolant accident (LOCA),
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Conclusion The NRC staff remained concerned that the opening of the cross ties would allow the third pump to potentially be affected by an unknown MUT low level condition.
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The inspector considered this an inspector follow item, pending additional review.
(IFl 98-02-03)
IV. Plant SuDDort l
i R1 Radiological Protection and Chemistry (RP&C) Controls (71750)
The inspector conducted plant tours during the period and did not identify any
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significant negative housekeeping or radiological control issues.
l P8 Miscellaneous EP issues (92904)
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P8.1 (Closed) Non-Cited Violation: Criticality Accident Requirements (EA 98-112)
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las2ection Scope This refers to the inspection at Three Mile Island Units 1 and 2 described in
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L Inspection Report Nos. 50-289/97-01 and 50-320/97-01, issued on March 20, 1997. As a result of that inspection, a Non-Cited Violation was assigned for the l
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f ailure to meet the requirements of 10 CFR 70.24, Criticality Accident Requirements or to have an NRC approved exemption to the requirement.
10 CFR 70.24 requires that each licensee authorized to possess more than a small amount of special nuclear material (SNM) maintain in each area in which such
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materialis handled, used, or stored a criticality monitoring system which will l
energize clearly audible alarm signals if accidental criticality occurs. The purpose of l
10 CFR 70.24 is to ensure that, if a criticality were to occur during the handling of SNM, personnel would be alerted to that fact and would take appropriate action.
Most nuclear power plant licensees were granted exemptions from 10 CFR 70.24 during the construction of their plants as part of the Part 70 license issued to permit the receipt of the initial core. Generally, these exemptions were not explicitly renewed when the Part 50 operating license was issued, which contained the combined Part 50 and Part 70 authority. In August 1981, the Tennessee Valley Authority (TVA), in the course of reviewing the operating licenses for its Browns Ferry facilities, noted that the exemption to 10 CFR 70.24 that had been granted during the construction phase had not been explicitly granted in the operating license. Byletters dated August 11,1981, and August 31,1987, TVA requested an exemption from 10 CFR 70.24. On May 11,1988, NRC informed TVA that "the previously issued exemptions are still in effect even though the specific provisions of the Part 70 licenses were not incorporated into the Part 50 license."
Notwithstanding the correspondence with TVA, the NRC has determined that, in cases where a licensee received the exemption as part of the Part 70 license issued during the construction phase, both the Part 70 and Part 50 licenses should be examined to determine the status of the exemption. The NRC view now is that unless a licensee's licensing basis specifies otherwise, an exemption expires with the expiration of the Part 70 license. The NRC intends to amend 10 CFR 70.24 to provide for administrative controls in lieu of criticality monitors, b.
Conclusion As described in the IR 97-01, the facility was in violation of 10 CFR 70.24 and a Non-Cited Violation was assigned. Numerous other facilities have similar circumstances. The NRC has reconsidered this violation and concluded based on the information discussed above that, although a violation did exist, it is appropriate to exercise enforcement discretion for Violations involving Special Circumstances in accordance with Section Vil B.6 of the " General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600. The bases for exercising this discretion are the lack of safety significance of the failure to meet 10 CFR 70.24;the failure of the NRC staff to recognize the need for an exemption during the licensing process; the prior NRC position on this matter documented in its letter of May 11,1988, to TVA concerning the lack of a need for an exemption for the Browns Ferry plant; and finally, the NRC's intention to amend 10 CFR 70.24 through rulemaking to provide for administrative controls in lieu of criticality monitors.
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V.
Manaaement Meetinos X1 Exit Meeting Summary At the conclusion of the reporting period, the resident inspector staff conducted an exit meeting with GPUN management or June 2,1998, summarizing Unit 1 inspection activities and findings for this report period.
GPUN staff comments concerning the issues in this report were documented in the applicable report section. No proprietary information was identified as being included in the report.
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INSPECTION PROCEDURES USED IP 37551 Onsite Engineering IP 40500 Effectiveness of Licensee Controls in identifying, Resolving, and Preventing Problems IP 61726 Surveillance Observations IP 62707 Maintenance Observation IP 71707 Plant Operations IP 71750 Plant Support Activities IP 92901 Followup - Plant Operations IP 92902 Followup - Maintenance IP 92903 Followup - Engineering IP 92904 Followup - Plant Support ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 50-289 URI 98-02-01 Potential testing deficiencies in the FHBESF ventilation system.
IFl 98-02-03 Makeup System Suction Alignment issues
Closed 50-289 LERs 98-002-00/-01 Missed Spent Fuel Pool Sample Following a Water Addition.
LER 98-004-00 and NCV 98 02-02 Reactor Building Spray Inoperable due to Control Room Switch Deficiency eel 97-070 item 07014 Testing of Molded Case Circuit Breakers.
EA 98-112 Enforcement Discretion - Criticality Accident Requirements Withdrawn: 50-289:
NCV IR 97-01 Criticality Accident Requirements l
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LIST OF ACRONYMS USED BS Reactor Building Spray (ECCS)
. Corrective Action Process CR Control Room CFR Code of Federal Regulations DBD Design Basis Documents DH Decay Heat Removal (ECCS)
DR Decay Heat River (ECCS)
EDG Emergency Diesel Generator ESF.
Engineered Safety Feature FHB Fuel Handling Building FHBESF Fuel Handling Building Engineered Safety Feature Ventilation FHBNV Fuel Handling Building Normal Ventilation GL Generic Letter GPUN GPU Nuclear IFl Inspection Followup Item IR
Inspection Report
JO
Job Order
LER
Licerisee Event Report
Motor Control Center
MU
Makeup
MUT
Makeup Tank
Non-Cited Violation
NRC
Nuclear Regulatory Commission
Preventive Maintenance
Plant Review Group
Potential Transformers
QV-
Quality Verification
Radiological Control Area
RP-
Radiation Protection
Spent Fuel Pool
TS
Technical Specification
Updated Final Safety Analysis Report
Unresolved item
Violation
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