IR 05000289/1998008
| ML20199G745 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/12/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20199G743 | List: |
| References | |
| 50-289-98-08, 50-289-98-8, NUDOCS 9901250003 | |
| Download: ML20199G745 (20) | |
Text
e
~
.
.
U.S. NUCLEAR REGU:.ATORY COMMISSION REGION 1
.
Docket No.
50-289 License No.
DPR-50 Report No.
98-08 Licensee:
GPU Nuclear, Inc. (GPUN)
Facility:
Three Mile Island Station, Unit 1 Location:
P. O. Box 480 Middletown, PA 17057 Dates:
November 1 through December 26,1998 Inspectors:
Wayne L. Schmidt, Senior Resident inspector Craig W. Smith, Resident inspector Neil S. Perry, Project Engineer James M. Trapp, Senior Reactor Analyst Paul H. Bissett, Senior Operations Engineer David R. Desaulniers, Human Factors Assessment Branch, NRR Approved by:
Peter W. Eselgroth, Chief Projects Branch No. 7
'
Division of Reactor Projects 9901250003 990112
'
PDR ADOCK 05000299
'
G PDR l
.
-
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -_
_ _ _ _ _ _
_
_
.
.
EXECUTIVE SUMMARY Three Mile Island Nuclear Power Station Report No. 50-289/98-08 This integrated inspection included aspects of licensee operations, maintenance and surveillance, engineering, and security. The report covers a seven week period of resident inspection; in addition, it includes the results of an announced inspection by a several inspectors in the area of operator workarounds.
GPU Nuclear, Inc. (GPUN) operated Three Mile Island (TMI) Unit 1 at 100% power throughout the inspection period.
Operations The control room staff operated the unit safely over the period, responding well to several minor plant conditions. Good supervision of control room activities was observed during routine operations and surveillance testing. (Section 01)
The control room operators responded well in identifying and analyzing changes in reactor coolant drain tank and makeup tank levels during preventive maintenance in the reactor building. (Section 01.1)
Operators responded well to finding the main bearing lube oil booster air isolation valve, for the "A" emergency diesel generator (EDG) closed vice open as expected. Operators and engineering appropriately determined that the EDG would have been operable in this condition. While this mispositioning was non-consequential, it raised concern since it occurred on safety-related equipment and there have been other examples in the recent past of mispositionings on non-safety equipment. (Section 01.2)
The licensee had established a process for tracking, evaluating, and resolving operator workarounds. The individual and cumulative effect of existing operator workarounds did not adversely impact the ability of operators to safely operate the plant. Operator work trounds were resolved in a timely manner commensurate with their safety signd.cance. GPUN planned to review several deficiencies concerning the assessment of burden and inclusion of several potential workarounds in the program. (Section 08.1)
Maintenance GPUN conducted the observed maintenance activities weliincluding engineered safeguards actuation system (ESAS) relay replacement and individual safety related battery cell charging to correct an identified low electrolyte specific gravity condition. Observed surveillance activities including reactor protection system, ESAS, and control rod drive testing were conducted properly. (Section M1)
Improper isolation of reactor coolant pump sealleakoff flow transmitter, during preventive maintenance caused an unexpected increase in Reactor Coolant Drain Tank level and a decrease in MUT level. The inspector considered the improper isolation of the flow ii
'
-
-
-
-
.
.... _
o
.
..
.
.
._ _ _
. _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _
_
.
instrument an inspection follow-up item (IFI), pending additional review of the isolation and tagging procedure. (IFl 98-08-01)(Section M1)
GPUN initiated appropriate actions to identify the cause for the ESAS relay coil failures.
The inspector considered this an IFl pending identification of the root cause and implementation of corrective actions to prevent recurrence. (IFl 98-08-02)(Section M2.1)
The inspector found that the method of testing the EDG upon a simulated loss of offsite power with the output breaker in the pull-to-lock position during certain portions of the test was acceptable and met the technical specification testing requirements. (Section M8.2)
Enoineerina System engineers performed wellin response to several equipment issues including:
providing operability information for the EDG main bearing tube oil air boost valve mispositioning, during ESAS relay replacement, and in generating and completing an action plan to individually charge a safety related station battery cell. (Section E1)
GPUN took appropriate actions to correct previous engineering prograrn issues with the quality classification list (OCL) and environmental qualification (EQ) issues. (Section E1)
Plant Support During evening hours the inspectors conducted a site protected area walkdown, including observations of security boundaries and detections aids. The inspectors found the guard force members in place to respond, using properly operating detection aids. Protected area lighting was adequate to allow visual and remote observations. (Section S1)
iii l
- _ _ _ _ _ _ _
..
-
-
.
..
..
.
.-
. _ _ _ _ - - _ - -
. - -..
..
l
,
TABLE OF CONTENTS I
EX ECUTIVE S U M M ARY.............................................. ii
i TABLE O F C O NTENT S.............................................. iv
,
!
l. Operations
....................................................1
Conduct of Operations.................................... 1
'
01.1 Unexpected increase in Reactor Coolant Drain Tank Level and Decrease in Makeup Tank Level........................ 1
01.2 Emergency Diesel Generator Valve Found Out of Position....... 2 (
Miscellaneous Operations issues............................. 3
!
08.1 Operator Workarounds............................... 3 II. M aint e n a nc e................................................... 6
M1 Conduct of Maintenance................................... 6
'
M2 Maintenance and Material Condition of Facilities and Equipment....... 7
M2.1 Engineered Saieguards Actuation System Relay Coil Failures.... 7 M8 Miscellaneous Maintenance issues............................ 7 M8.1 (Closed) Licensee Event Report 9 8-001 -00................. 7 M8.2 (Closed) Unresolved item 9 7-0 9 -04...................... 8
-
lll. Engine e ring................................................... 9
'
E1 Conduct of Engineering
...................................9 E8 Miscellaneous Engineering issues............................ 10 E8.1 (Closed) Escalated Enforcement item 97-256/03023......... 10 E8.2 (Closed) Escalated Enforcement item 97-256/03033......... 11 E8.3 (Closed) Escalated Enforcement item 97-256/05013......... 11 E8.4 (Closed) Licensee Event Report 97-002 00................ 12 E8.5 (Closed) Licensee Event Report 97-003-00 and 01........... 12 E8.6 (Closed) Licensee Event Report 97-004-00................ 12 E8.7 (Closed) Licensee Event Report 97-010-00................ 13 E8.8 (Closed) Licensee Event Report 9 8-00 3-00................ 13 E8.9 (Closed) Unresolved item 9 7-0 6-0 3..................... 14 IV. Plant Support
................................................14 S1 Conduct of Security..................................... 14 X. Manageme nt Meeting s.......................................... 14
,
X1 Exit Meeting Summ ary................................... 14 INSPECTION PROCEDURES USED..................................... 15 ITEMS OPENED, CLOSED AND DISCUSSED.............................. 15 i
,
LIST O F ACRO NYMS USED.......................................... 16 iv
.
,
,
.
Report Details
-
Summarv of Plant Status GPU Neclear, Inc. (GPUN) operated Three Mile Island Unit 1 (TMI) at 100% power throughout the inspection period.
1. Operations
Conduct of Operations (71707)
The control room staff opere,ted the unit safely over the period, responding well to several minor plant conditions. Good supervision of control room activities was observed during routine operations and surveillance testing.
01.1 Unexoected increase in Reactor Coolant Drain Tank Level and Decrease in Makeun Tank Level a.
Inspection Scoce (71707)
On December 16 the inspector observed control room response to an unexpected increase in reactor coolant drain tank (RCDT) level and a decrease in makeup tank (MUT) level during work on a reactor coolant pump (RCP) seal leakoff flow transmitter in the reactor building (RB).
b.
Observations and Findinos Control room personnel observed the changing levels in the RCDT and MUT and took appropriate actions to add water to the MUT and to analyze the possible causes. Through discussions with the instrument and control (l&C) technicians in the RB at the time GPUN determining that a RCP sealleakoff flow indicator was not properly isolated during removal for preventive maintenance. The bypass valve for this detector was not open prior to closing the two isolation valves. This caused isolation of the #1 sealleakoff, forcing more water out the #2 sealleakoff, overflowing the standpipe into the RCDT. The increase in water flow to the RCDT and the decrease in flow to the MUT accounted for the changes in tank levels.
The operators properly documented this issue in the GPUN corrective action process (CAP.)
c.
Conclusion The control room operators responded wellin identifying and analyzing changes in RCDT and MUT levels during preventive maintenance in the RB.
_-
l
01.2 Emeroency Diesel Generator Valve Found Out of Position
,
a.
Insoection Scope (71707)
The inspector observed GPUN's response to an auxiliary operator finding the main bearing lubricating oil (lube oil) booster air isolation valve, EG-V-173A, for emergency diesel generator (EDG) EG-Y-1 A, shut on December 6. This normally open valve supplies an immediate source of lube oil to the main bearing in the event of a fast start from cold conditions. The control room directed the immediate
,
opening and independent verification of the correct position.
'
b.
Observations and Findinas The operators properly documented the issue on a CAP and completed an accurate operability determination. Using engineering input, operators determined that the EDG would have been operable with the valve closed. The air booster functions to supply an immediate source of tube oil to the main bearing in the event of a fast start from cold conditions. Once the dieselis up and running, the normallube oil systems function to supply lube oil to the main bearing. The system engineer determined that not having an immediate supply of lube oil to the main bearing in conjunction with the diesel being subjected to a fast start would have resulted in only slight wear to the main bearing. GPUN determined that EG-Y-14 remained operable during the time EG-V-173A was shut. The inspector concurred with GPUN's assessment.
GPUN documented the valve out of position in their currective action system to determine the cause for the valve mispositioning. EG-V-173A was last operated during EG-Y-1 A surveillance testing on November 11.
The inspector identified that there have been other instances of valves or switches being found out of position in the recent past. This was the first such occurrence
,
directly on a safety-related piece of equipment. None of the other mispositionings j
resulted in any consequences to the operation of the facility.
GPUN determined the valve mispositioning was not a deliberate act. Specifically, the determination was made based on identifying when the valve was last operated and verifying there were no maintenance activities performed on the valve since that time; noting that there was no evidence of sabotage, and verifying that the
,
similar valve on the other EDG was in the correct position. The valve was last operated and verified to be in its correct position during periodic diesel generator surveillance testing conducted on November 11. GPUN entered this event into its corrective action program and was conducting further investigations to determine the cause of the valve mispositioning.
_
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
,
!
i
c.
Conclusions Operators responded well to finding the main bearing lube oil booster air isolation valve, for the "A" EDG closed vice open as expected. Operators and engineering
,
appropriately determined that the EDG would have been operable in this condition.
While this mispositioning was non-consequential, it raised concern since it occurred on safety-related equipment and there have been other examples in the recent past of mispositionings on non-safety equipment.
Miscellaneous Operations issues 08.1 Ooerator Workarounds a.
Insoection Secoe (Tl2515/138)
The inspectors reviewed GPUN's operator workaround program to verify: a definition consistent with NRC expectations, proper identification, assessment of individualitems, and proper assessment of the cumulative effect of workarounds on safe operation of the plant. The inspectors also reviewed the quality of corrective actions taken to resolve workarounds.
b.
Observations and Findinas
Procedures and Criteria The licensee definition of an operator workaround as "a component or system deficiency which causes station personnel to take compensatory action which results in an additional burden to that person," was generally consistent with the NRC definition. The administrative procedure further defined a deficiency as a malfunction, a design deficiency, or trying to use a component or system in a way it wasn't designed to be used. This definition had two minor differences from the NRC definition:
It was broader in that it includes burdens on any plant personnel rather than
-
just operators.
It was somewhat more limiting in that it refers to " component or system
-
deficiencies" whereas the definition used by the NRC refers to " degraded or non-conforming conditions" and consequently includes structural and environmental (e.g., radiological) conditions that might not be captured using the licensee's definition.
This assessment of operator burden was a key element of the operator workaround process review. The administrative procedure stated that a review of the operator workarounds would assess the burden of the individual operator workarounds, and the combined burden of multiple operator workarounds. The operations engineer stated that he was responsible for assessing the burden of the operator workarounds. The inspectors noted two deficiencies:
.
.
.
.
.
..
_
_ _ _ _ _ _ _.
..
_-_ _ - _ _ _ _ _ _ _ -
I
.
The assessment of operator burden was not documented. The operations
-
engineer stated that the program would be revised to include documented assessment of operator burden.
The guidance for assessing operator workarounds addressed operator burden
-
but did not explicitly include impacts on personnel errors, system reliability / availability, increase in the probability to induce abnormal conditions, or impact on the response to abnormal or emergency conditions.
The operations engineer stated that these items were considered when conducting the operator burden assessment.
- Identification of Ooerator Workarounds The inspectors assessed the licensee's performance in identifying operator workarounds. The workaround process relied on plant personnel to identify workarounds during the course of their daily activities and did not include periodic reviews of procedures, logs, or work requests for this purpose. The conduct of operations procedure stated that all plant personnel were encouraged to submit workarounds into the tracking database. The inspectors did not directly assess whether most personnel were aware of the means for identifying workarounds but did note that the workarounds had been identified by a small number of individuals.
In general, the list of open operator workarounds (11) was comprehensive, covering a wide range of plant systems. The team found that the plant operators were familiar with the workarounds being tracked. The inspectors concluded that the licensee had an adequate process for the identification of operator workarounds.
Through interviews, observations of plant operations, and reviews of selected operating procedures, the inspectors identified a few items that appeared to meet the licensee's definition of an operator workaround, but were not included in the program. These items included:
Operators must take manual control of the emergency feedwater (EFW) flow
-
control valves to control steam generator water level following automatic actuation of the EFW system.
Auxiliary operators were periodice.!Iy required to perform duties as a fire
-
watch as compensatory measures for degraded fire safety equipment.
A tygon tube had been installed to serve as a temporary locallevelindication
-
during certain spent resin tank operations.
A fire watch was required to be manned during operation of the station
-
blackout diesel generator.
The inspectors did not consider any of these items to be safety significant, nor did they pose an unreasonable burden on the ability of the operators to perform their duties. The operations engineer stated that he would consider including the potential workarounds, identified by the inspectors, into the program.
_ _ _ _ _ _ _ _ _ _ _ _ _ -
. - - - -
_ _ - _ _ _ _ - _ _ - __
_ _ _ _ - _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _
_
__
- Assessment of Individual Workarounds The inspectors reviewed the 11 open operator workarounds to assess their individual impact on plant operational safety, finding that nine had negligible operational significance. The two workarounds that had minor significance were an oil leak on an RCP and a failed nuclear instrumentation (NI) channel. Neither of these workarounds were correctable during plant operation. Corrective actions were planned for the next scheduled outage.
The "D" RCP upper bearing had a small oilleak. The Appendix R oil collection system tank collected the approximate five gallons per week of oilleakage, resulting in no additional risk to plant safety equipment. The operator compensatory actions included adding ten gallons of oil, approximately every two weeks and draining the Appendix R collection tank pe.riodically. The oillevel decrease was monitored each shift from the control room computer data log and an alarm would annunciate in the control room if a low level was reached. Oil was routinely added prior to the alarm annunciating so this condition did not result in a nuisance alarm. The evolution to add oil takes approximately 30 minutes and results in an individual radiation exposure of approximately 2-5 mrem. Compensatory measures were in place to refill the reservoir expeditiously should the leakage rate increase unexpectedly; however, to date, the rate of level decrease has remained steady. The RCPs are not safety-related. Therefore, the ability to respond to abnormal conditions was not significantly impacted in addition, the other RCPs were not experiencing oil leakage and would presumably remain available even if the "D" RCP was secured.
The failure of a safety-related Ni power range detector (N17) resulted in disconnecting of its input to the "C" reactor protection system (RPS) cabinet and the placing of that cabinet in manual bypass in accordance with technical specifications (TS). The required compensatory actions necessary during l&C equipment calibrations were appropriately proceduralized. The control room operators were not required to take any compensatory measures in response to the bypassed RPS channel during normal or transient conditions. Classroom and simulator training appropriately included the Nl failure and RPS channel bypass.
The inspectors determined that the present operator workarounds did not adversely affect the operators ability to safely operate the plant. Appropriate compensatory actions, when needed, were in place to effectively minimize the effects of the workarounds.
e Cumulative Effect of Operator Workarounds The inspectors independently assessed the cumulative operator burden of the existing workarounds and verified the operation engineer's conclusion that the operator burden was negligible. There was also no appreciable risk associated with the compensatory actions being implemented. Only the N17 detector failure was associated with safety-related equipment. Other workarounds identified issues with infrequently operated equipment such as fuel handling equipment or waste evaporators. Other operator workarounds were tracking equipment deficiencies l
l
.
....
-
with plant support systems, such as sewage treatment and well water. The majority of the workarounds required little or no operator compensatory actions.
The inspectors concluded that the licensee was taking effective actions to eliminate significant operator workarounds.
- Resolution of Operator Workarounds The inspectors independently verified a sample of actions that the licensee had taken to resolve identified operator workarounds. The timeliness of corrective actions was commensurate with the safety significance of the identified workaround. Licensed operators and auxiliary operators interviewed stated that workarounds were routinely resolved in a timely manner, with particular attention applied to resolving safety significant workarounds. A review of all open and closed workarounds for the past five years indicated that GPUN has met its goal of resolving issues within at least two years.
c.
Conclusions The licensee had er,tablished a process for tracking, evaluating, and resolving operator workarounds. The individual and cumulative effect of existing operator workarounds did not adversely impact the ability of operators to safely operate the plant. Operator workarounds were resolved in a timely manner commensurate with their safety significance. GPUN planned to review several deficiencies concerning the assessment of burden and inclusion of several potential workarounds in the program.
II. Maintenanca M1 Conduct of Maintenance (61726,62707)
GPUN conducted the observed maintenance activities well including engineered safeguards actuation system (ESAS) relay replacement and individual safety related battery cell charging to correct an identified low electrolyte specific gravity
condition. Observed surveillance activities including RPS, ESAS, and control rod drive testing were conducted properly.
Improper isolation of an RCP seal leakoff flow transmitter, during preventive maintenance caused an unexpected increase in RCDT level and a decrease in MUT level, as discussed in Section 01.1 The inspector considered the improper isolation of the flow instrument an inspection follow-up item (IFI), pending additional review of the isolation and tagging procedure. (IFl 98-08-01)
.
.
M2 Maintenance and Material Condition of Facilities and Equipment (62707)
M2.1 Enoineered Safeouards Actuation System Relav Coil Failures a.
Insoection Scone The inspector reviewed actions taken by GPUN in response to recent failures of relay coils in the ESAS.
b.
Observations and Findinos During quarterly ESAS testing conducted in December, two relays fai!cd to fully reposition when reenergized. The relay coils deenergize upon receipt of an ESAS signal allowing a spring to position the relay contacts to perform their ESAS functions. Upon removal of the ESAS signal, the coils reenergize and the relay repositions to its normal or standby state. The two coils that failed did not fully reposition to their standby state resulting in abnormal current flow in the coils, subsequent overheating, and eventual failure. In one case, the coil overheated to the extent that it damaged adjacent electrical contacts.
There have been six similar occurrences of ESAS relay coil failures in the past 36 months. In all cases, the relay failed upon being reenergized to its normal or standby state following system te:: ting. In no cases, did a relay fail to properly reposition from its deenergized state upon receipt of a simulated ESAS signal.
GPUN documented the ESAS relay coil failures in its CAP. GPUN further designated the ESAS system as requiring a performance improvement plan and additional monitoring in accordance paragraph a(1) of 10 CFR 50.65, Maintenance Rule. The two relay coils that failed in December were sent to the manufacturer for analysis in order to establish a root cause for the failures.
c.
Conclusion GPUN initiated appropriate actions to identify the cause for the ESAS relay coil failures. The inspector considered this an IFl pending identification of the root cause and implementation of corrective actions to prevent recurrence. (IFl 98-08-02)
M8 Miscellaneous Maintenance issues (90712,92902)
M8.1 (Closed) 1.icensee Event Report 98-001-00: Unit 2: Flood Barriers Breached Between the Turbine Buildino and the Control Buildino Area Due to inadeouste Fieldwork Documents a.
Insoection Scoce The inspector reviewed licensee event report (LER) 98-001-00, dated July 2,1998, to verify GPUN completed a comprehensive evaluation and took adequate corrective
,.
....
_..
.
.. _
_ _ _ _ _ _ _ _ - - - - - - - _ _ _ _ _ _ _ _ _ _ _.
actions in response to the licensee identifying breached flood barriers between the Unit 2 turbine building and control building area.
b.
Observations and Findingg On June 4,1998, GPUN found several pipes penetrating the wall between the turbine building basement and the control building in Unit 2 to be open on both
'
sides of the wall. This condition was contrary to the Unit 2 post-defueling monitored storage safety analysis report (PDMSSAR) which requires entrances to the control building area to be watertight or provided with flood panels and openings that are potentialleak paths to be sealed. The pipe openings were the result of dismantlement work ongoing at the time of the discovery.
GPUN identified the root cause of the event as a failure of the work planning process to include adequate controls for the PDMSSAR in dismantlement work packages. As an immediate corrective action, GPUN stopped all work on systems that could effect the Unit 2 flood barrier and conducted a field walkdown of the affected area to determine the nature and extent of the problem. By June 19, 1998, all identified penetratiens and openings had been sealed with materials capable of withstanding the maximum probable flood level. To prevent recurrence, GPUN made changes to the work control process to require review of the planned work against the requirements of the PDMSSAR. In addition, the method of lay up of PDMS deactivated systems was reviewed to determine the potential for connection of these systems to the outside environment, identifying no other flood pathways. The inspector reviewed GPUN's response to this LER, including a field walkdown of the Unit 2 turbine building and control building area basement, and found these corrective actions adequate.
C.
Conclusion GPUN took appropriate actions in response to the Unit 2 control buikiing flood barriers breach, as documented in LER 98-001-00.
M8.2 (Closed) Unresolved item 97-09-04: Emeroency Diesel Generator Testina Durina Simulated Accidents a.
Inspection Scope The inspectors previously identified a concern that Surveillance Procedure 1303-11.10, Emergency Safeguards (ES) System Emergency Sequence and Power Transfer Test, required the EDG output breaker to be placed in a pull-to-lock position preventing automatic closure of the breaker while conducting certain portions of the test. The inspector reviewed the surveillance procedure against the TS requirements for emergency power system periodic tests to determine the appropriateness of testing with the EDG output breaker in the pull-to-lock position.
l
__
.
b.
Observations and Findinas The inspector reviewed the surveillance procedure against the applicable TS testing requirements, and discussed the testing sequence with the responsible system engineer. The system engineer explained that the test was conducted with the EDG output breaker initially in the pull-to-lock position to allow for verification of proper electrical system response to a simulated loss of offsite power (LOOP). The surveillance procedure verifies certain loads are automatically shed from the electrical buses in response to the LOOP prior to taking the output breaker out of the pull-to-lock position allowing automatic closure of the breaker and sequential loading of the EDG, if the surveillance procedure were not conducted in this manner, it may not be possible to verify the automatic load shedding feature prior to the EDG output breaker closing and reenergizing the safety related loads.
The surveillance procedure was written such that it recorded the EDG automatic start time and added it to the time for EDG automatic loading sequence. The EDG automatic start time begins at the initiation of the simulated LOOP with the EDG output breaker in the pull-to-lock position and stops when the EDG ready to load light energizes. The automatic load sequencing time starts when the EDG output breaker is taken out of pull-to-lock and stops when the loading sequence is completed. The cumulative time was compared against the TS requirement to verify the EDG block loads upon a simulated LOOP in less than or equal to 30 seconds. The inspector reviewed the applicable EDG control system drawings finding that this method tested all portions of the controllogic. The inspector found this method of verifyra the TS requirement acceptable and closed this unresolved item (URI).
'
c.
Conclusion The inspector found that th:.aethod of testing the EDG upon a simulated LOOP with the output breaker in the pull-to-lock position during certain portions of the test was acceptable and met the TS testing requirements.
Ill. Enaineerina E1 Conduct of Engineering (37551)
System engineers performed wellin response to several equipment issues including:
providing operability information for the EDG main bearing lube oil air boost valve mispositioning, during ESAS relay replacement, and in generating and completing an action plan to individually charge a safety related station battery cell.
GPUN took appropriate actions to correct previoe: engineering program issues with the quality classification list (OCL) and environmental qualification (EO) issues.
_.
._ _
. _ _ _ _ _. _.
_ _. _ _ _ _ _ _. _ _ _ _ _
_ _ _
,
E8 Miscellaneous Engineering issues (90712,92903)
E8.1 (Closed) Escalated Enforcement item 97-256/03023: Inadeaucte Corrective Actions Reaardino Comoonents Safety Classification This violation resulted from the failure to take timely and appropriate corrective actions on quality assurance (QA) findings regarding inappropriate equipment classification downgrades. Between June 1,1992, and March 2,1997, GPUN did not correctly identify deficiencies in the supporting documentation for the safety classification of components to preclude repetition of problems with insufficient documentation in support of QCL activities. The inspector reviewed the corrective actions taken, as documented in GPUN's reply to this Notice of Violation (NOV),
dated December 15,1997, and contained in CAP T1997-0568.
GPUN determined that a persistent organizational resistance to effective oversight existed as indicated by concerns in: escalation of quality deficiencies; conflict i
avoidance / resolution; misinterpretation of " performance-based QA"; and misinterpretation of the principles of Teamwork and Leadership. Corrective actions i
included:
Issuance of guidance to clarify expectations on resolving and escalating
-
quality deficiencies; A review of all outstanding quality deficiency reports (ODRs) to ensure
-
proper escalation; and, Revisions to the CAP pocedure to explicitly incorporate escalation
-
requ:rements and establishment of expectations on the form, content, use, ownership, and oversight of the CAP. NRC inspection Report (IR) 97-10 noted that the CAP had improved, but further attention was warranted. The inspectors observed that the corrective action program was revised in 1998,
and performance of the new program was being appropriately monitored.
To address conflict avoidance / resolution, GPUN management established and
-
communicated responsibilities and expectations. Division vice presidents at TMI, Oyster Creek and in the corporate offices completed presentations to onsite staff in early 1998. Workshops were held with Nuclear Safety Assessment (NSA) and Engineering in 1997 and 1998, and monitoring was implemented to determine the effectiveness of corrective actions. The results of an independent assessment of NSA confirmed that the concerns have been addressed.
The working definition of " performance-based QA" was clarified in a memo
from NSA to management at TMI, Oyster Creek and the corporate offices, dated December 1997, and communicated to the organization to avoid any future misunderstandings. Team building workshops were conducted with NSA and Engineering earlier in 1998, to clarify Teamwork and Leadership training in regards to the potential misinterpretation or misapplication of these principles. Additionally, revisions to engineering procedure EP-011 formalized the QCL process and included written, detailed standards related to component and program changes.
_.
.
-
,
---_
._.
_ _
The inspector concluded that these corrective actions adequately addressed the concerns and closed this escalated enforcement item.
E8.2 (Closed) Escalated Enforcement item 97-256/03033: Inadeauate Corrective Actions Recardino Reactor Buildina Emeroency Coolina Fans This notice of violation (NOV) resulted from the failure to take timely and appropriate corrective actions for an environmental qualification deficiency associated with the reactor building emergency cooling (RBEC) fans. On March 21, 1997, plant personnel identified that AH-E-1 A was not environmentally qualified, in that the application of heat shrink.ubing left a smalllength of exposed conductor at the connection to the fan motor. Plant personnel failed to conduct sufficient additional reviews to identify and resolve the similar condition for the other two fans i
until April 24,1997, resulting in these two fans being technically inoperable due to lack of EQ. The inspector reviewed the corrective actions taken regarding this violation, as documented in GPUN's NOV response, dated December 15,1997.
GPUN reviewed procedures to assure they contained appropriate provision for timely reporting documentation and resolution of operability concerns, and engineering groups were trained on those requirements. GPUN developed an onsite EQ engineer position to improve communications between onsite and corporate engineering, and to ensure appropriate EQ resources onsite. Additionally, the onsite EQ engineer identified no significant discrepancies during a walkdown of selected components during the 1997 refueling outage to assure EQ configuration requirements. Finally, Engineering Procedure EP-031, Equipment EQ Program, was revised to provide i
improved operability determination guidance and supporting documentation for EQ
,
components. The inspector discussed tne corrective actions taken with the onsite EQ engineer, and concluded that they appropriately addressed the concerns and closed this escalated enforcement item.
E8.3 (Closed) Escalated Enforcement item 07-256/05013: Reactor Buildina Emeraenev Coolina Fans Not Environmentally Qualified This NOV resulted from the failure to ensure EQ of the RBEC fans. From March 17, 1986, until March 24,1997, the three RBEC fans were not EQ by testing and/or analysis for post-loss of coolant accident (LOCA) RB atmospheric conditions. The application of heat shrink tubing left a smalllength of conductor at the motor power connector to each of the fan motors exposed. As a result, the RBEC fans were technically inoperable since they could not meet EQ requirements. The inspector reviewed the corrective actions taken regarding this violation, as documented in GPUN's NOV response, dated December 15,1997.
Plant personnel replaced the cable connection for the AH-E-1 A fan motor with an EQ configuration on March 24,1997, according to procedure 1420-AH-1, AH-E-1 A/B/C Motor Maintenance. The cable connections on both the AH-E-1B and 1C fan motors were temporarily repaired with an EQ configuration on April 24,1997; permanent replacements were completed during the Fall 1997 refueling outage.
Additionally, engineering documentation was revised to clearly delineate the EQ
-.
-
- - - - - - - - - - - - -
- - - - - - - - - - - - - - - -
.
l
requirements, include a description of the acceptable configuration for the termination, and provide an as-built configuration of the cable connection.
Procedure 1420-AH 1 was revised effective February 20,1998, to identify the requirements for restoration of the connection during any future maintenance activities.
The inspector reviewed the revised procedure and engineering documentation, and discussed the enhancements with the onsite EQ engineer. Corrective actions taken were adequate to address the concerns; this escalated enforcement item is closed.
E8.4 (Closed) Licensee Event Report 97-002-00: Potential Inability of the Startuo Feedwater Block Valves to Fully Close Followino a Main Steam Line Break Due to
.Aotor Operated Valve Proaram Weaknesses The inspector conducted an in-office review of this LER. The issue and LER were reviewed and documented in NRC IR 97-07, which focused on the status of the Generic Letter 89-10 motor-operated valve program. That inspection did not identify any significant issues regarding the LER. This LER is closed.
E8.5 (Closed) Licensee Event Report 97-003-00 and 01: Potential Overoressurizraion of Makeuo Pumo Pioina Due to inadeauate Test and Ooeratino Procedures The inspector conducted an in-plant and in-office review of this LER initially written in March 1997. The potential overpressurization of the "C" makeup pump (MUP)
suction piping was identified as a result of the NRC's architect engineering design team inspection in December 1996. Initial NRC review found the LER inadequate, in that it did not properly discuss the situation leading to the problem. This issue was the subject of NOV 97-07-01, which was closed in IR 97-09, following GPUN issuance of revision 01 to the LER.
The major corrective action taken to resolve the overpressurization was the opening of the MUP suction cross-connect valves during the Fall 1997 refueling outage.
This valve positioning would clearly prevent the overpressurization of the piping.
An open iFi (98-02-03) exists concerning the adequacy of operating the system in this configuration. This LER is closed.
E8.6 (Closed) Licensee Event Reoort 97-004-00: Auxiliary and Fuel Handlina Buildina Ventilation Svstem Declared Inonerable Due to Questions on Quality Classification The inspector reviewed LER 97-004-00, dated April 4,1997, to verify that GPUN completed a comprehensive evaluation and took adequate corrective actions in response to the auxiliary and fuel handling building ventilation system (AFHBVS)
inoperability due to components that had been improperly downgraded from
" Regulatory Required" to the "Other" quality classification.
Through on-site inspection, the inspector verified GPUN took appropriate actions to change the quality classification for the affected components back to legulatory Required" with appropriate controls now being applied to system maintenance and
...
.
.
.
.
_ _ _ _ __
.-
_
_
--
-
.
-.
,
.
testing. In addition, GPUN reviewed all AFHBVS maintenance and testing conducted during the time period when the system was classified as "Other" and evaluated the impact of those activities on system operability. There were no impacts identified and the system was returned to an operable status.
GPUN took appropriate actions to correct the improper quality classification of the i
I AFHBVS, as documented in LER 97-004-00. This LER is closed.
E8.7 (Closed) Licensee Event Reoort 97-010-00: Pilot Operated Relief Valve inocerability Due to Beina Mis-wired and Failure to Perform Post-maintenance Test Followina i
Replacement Durina 11R Refuelina Outaae The inspector conducted an in-office review of this LER. The issue was initially documented in NRC IR 97 09 and resulted in a violation issued separately on January 27,1998. The LER properly described the event and the licensee initiated l
a comprehensive root cause evaluation and corrective actions. No new issues were identified in the LER. This LER is closed.
E8.8 (Closed) Licensee Event Reoort 98-003-00:Missina Thermo-Lao Barrier The inspector reviewed LER 98-003-00, dated March 19,1998, to verify GPUN completed a comprehensive evaluation and took adequate corrective actions in response to a conduit not prctected by a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire barrier as required by the TMI-1 fire hazards analysis report (FHAR).
On February 18,1998, while performing work in preparation for upgrading thermo-
lag fire barriers in the control tower chiller room, GPUN identified an inconsistency l
in the conduit arrangement. A field installation discrepancy dating back to initial
,
l plant construction resulted in a conduit arrangement being reversed from that l
shown on the original construction drawing. This discrepancy had been previously i
identified in 1982 and a change document, that correctly identified the conduit locations, was posted to the drawing. In 1987, while installing thermo-lag fire barrier material on one of the two full range nuclear instrument channel cables, the installers did not reference the 1982 change document, as required. This resulted in the required cable not being protected by a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire barrier. The TMI-1 FHAR required a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire barrier for protection of one of the two full range nuclear instrument channels to ensure the operators ability to monitor for a recriticality event, after the plant has been shut down in the event of a fire in the chiller room.
As a result of the thermo-lag installation error in 1987, neither of the two full range j
nuclear instrument channels were protected by the required 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire barrier.
GPUN took immediate actions to establish a fire watch in the effected area and modified the appropriate operating procedure to provide guidance on compensatory actions in the event that both channels of the full range nuclear instrument became inoperable. The correct conduit locations were identified in the field and verified against the as installed drawing. A 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated fire barrier was then installed on the correct full range nuclear instrument channel. The work was completed on
u
,_
L
February 13,1998. The inspector verified the field installation against the applicable plant drawings.
GPUN took appropriate actions in response to a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated fire barrier not being installed on one of the two full range nucles' instrument channels, as docui6ented in LER 98-003-00. This failure to r.ee tho requirements of the FHAR constitutes a license violation of minor signifiernce and is not subject to formal enforcement action. This LER is closed.
E8.9 (Closed) Unresolved item 97-06-03: Failure to Enter Possibly Dearaded Main Generator Outout Breaker Condition into the Corrective Actions Proaram The inspector reviewed the circumstances leading to the failure of a main generator circuit breaker and subsequent loss of offsite power on June 21,1997, with respect to whether a previously known degraded condition on the breaker should have been documented on a CAP.
The inspector found that while the condition identified could have been reported under the CAP, there were not specific requirements to document the possible degraded condition of a non-safety related piece of equipment in a CAP. The technician who identified it did discuss the condition with engineering as documented in LER 97-007-00. Since 1997, GPUN has implemented a new CAP which would also allow documentation of this type of inspection result. The inspector closed this URI.
IV. Plant Suoport S1 Conduct of Security (71707)
During evening hours the inspectors conducted a site protected area walkdown, including observations of security boundaries and detections aids. The inspectors found the guard force members in place to respond, using properly operating detection aids. Protected area lighting was adequate to allow visual and remote observations.
X. Mannaement Meetinos i
X1 Exit Meeting Summary Following the conclusion of the report period, the resident inspectors conducted an exit meeting with GPUN management on January 7,1999, summarizing the inspection activities and findings.
.
GPUN staff comments concerning the issues in this report were documented in the applicable report section. No proprietary information was included in thi'; report.
l
_ _ _ _ _ _ _ _ - - - - - - - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ - - - _ - - _ _ _ - - - - -,
,
t
INSPECTION PROCEDURES USED IP37551 Onsite Engineering Observations IP61726 Surveillance Observations IP62707 Maintenance Observations IP71707 Plant Operations IP90712 Inoffice Review of Written Reports of Power Reactor Facilities IP92902 Maintenance Followup IP92903 Engineering Followup Tl2515/138 (Closed) Operator Workarounds ITEMS OPENED, CLOSED AND DISCUSSED Ooened:
98-08-01 IFl Irnproper Isolation of a RCP leakoff Flow Instrument 98-08-02 IFl Failure of ESAS Relays to Properly Reenergize Closed:
97-256/03023 eel Inadequate Corrective Actions Regarding Components Safety Classification 97-256/03033 eel Inadequate Corrective Actions Regarding Reactor Building Cooling Fans 97-256/05013 eel Reactor Building Emergency Cooling Fans Not Environmentally Qualified 97-002-00 LER PotentialInability of the Startup Feedwater Block Valves to Fully Close Following a Main Steam Line Break Due to MOV Program Weaknesses
'
97-003-00,01 LER Potential Overpressurization of Makeup Pump Piping Due to inadequate Test and Operating Procedures 97-004-00 LER Auxiliary and Fuel Handling Building Ventilation System Declared inoperable Due to Questions on Quality Classification 97-010-00 LER Pilot Operated Relief Valve Inoperability Due to Being Mis-wired and Failure to Perform Post-maintenance Test Following Replacement During 11R Pefueling Outage 98-001-00 LER Unit 2; Flood Barriers Breached Between the Turbine Building and the Control Building Area Due to inadequate Fieldwork Documents 98-003-00 LER Missing Thermo-Lag Barrier 97-06-03 URI Failure to Enter Possibly Degraded Main Generator Output Breaker Condition into the Corrective Actions Program 97-09-04 URI Emergency Diesel Generator Testing During Simulated Accidents Discussed:
None
.
. -
-. - -
- ~.
.
_ -
-
,.
_-
.-
,
-
s
'
LIST OF ACRONYMS USED AFHBVS Auxiliary and Fuel Handling Building Ventilation System CAP Corrective Action Process EDG Emergency Diesel Generator eel Escalated Enforcement item
!
!
,
EQ Environmental Qualification ES Emergency Safeguards.
ESAS Engineered Safeguards Actuation System l
'FHAR Fire Hazards Analysis Report GPUN GPU Nuclear, Inc.
l&C Instrument and Control IFl Inspection Follow-up Item IR
Inspection Report
!
LER
Licensee Event Report
Loss of Coolant Accident
MUP
Makeup Pump
MUT
Makeup Tank
Motor-Operated Valve
NI
Nuclear instrumentation
NRC
Nuclear Regulatory Commission
<
Nuclear Safety Assessment
PDMSSAR
Post-Defueling Monitored Storage Safety Analysis Report
Post-Maintenance Test
Pilot Operated Relief Valve
-QA
Quality Assurance
i
l
QCL
Quality Classification List
ODR
Quality Deficiency Report
Reactor Building
i
RBEC
Reactor Building Emergency Cooling
Reactor Coolant Drain Tank
'
Reactor Coolant Pump
Reactor Protection Systern
Three Mile Island
TS
Technical Specification
Updated Final Safety Analysis Report
Unresolved item
'
<
l
i
r