IR 05000320/1976003
| ML19220C342 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/17/1976 |
| From: | Canter H, Davis A, Fasano A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19220C341 | List: |
| References | |
| 50-320-76-03, 50-320-76-3, NUDOCS 7904300449 | |
| Download: ML19220C342 (15) | |
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4 ci IE:I Form 12
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U. S. NUCLEAR RECULATORY CC'::tISSION
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i ug OFFICE OF INSPECTIO:: 2D C.TORCCL".T
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REGICM I IE Inspectica Report Nc:
50-320/76-03 Docket No:
50-320 Licensee:
n tocolitan 2.11sen Ceccany
_ Licensa No: C??R-66 Box 542
_ Priority:
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Readfaz, Pennsylvania 19603 Category:
B Safeguards Group:
Location:
S'lddletown, Pennsvivania (TMI -2)
Type of Licensee: FWR 2772 % (BW)
Routine, Announced Type of Inspection:-
February 24-27, 1976 Dates of Inspection:
Dates of Previous Inspection:
February 23-25, 1976 i
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Reporting Inspector:
fv A. N. Tasano, Reactor Inspector
.DAIE Acec=panying Inspectors: M.$.
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S "" O - 7 b H. L. Canter, Raactor Inspector DAIE DATE DATE
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Other Accenpanying Personnel:
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DATE M
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' Revieved By:
A.
B. Davis, Sect:.on Chief, Reactor Projects DATE Section No. 1
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SUMMARY OF YugDiCS
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Enf orce::ent Action Non t.
Othetr Sismificant Findim A.
Current 1.
Acceptable Items These are areas which were inspected on a sampling basis and
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findings did not involve an item of Noncocpliance, Deviation or Unresolved Item (except as noted):
a.
Test Program, Details 3.
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Test Organization, Details 4.
Test Program Ar*-inistration, Details 5.
c.
d.
Docu=ent Control, Details 6.
Design Changes and Modifications, Details 7.
e.
f.
Equipment Protection and Cleanliness, Setails 8.
g.
Test and Meas"rement Equipment, Details 9.
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h.
Training, Details 10.
1.
Turbine Trip Fr i 40 Power, Details 11.
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Test Procedure Verification, Details 12.
2.
Unresolved Items These are items for which more infor=ation is required to determine whether the items are acceptable or Ite=s of Non-compliance:
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a.
76-03-1: Addition of TP 160/1 to FSAR Table, Details 3.a.
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76-03-2: Addition of TF 380/1 to FSAR Table, Details 3.b.
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c.
76-03-3:, Field Instru=ent Control Log Developnent, Details 9.
d.
76-03-L: Code Safety Valve Testing, Details 13.
3.
Follovun Item This is an item of inspector's concern which requires additional research and will be rev'.eved in a subsequent report:
76- 03-4: Preoperational Personnel Training, Details 10.
B.
Status of 'reviously Unresolved It n Not inspected.
C.
Status of Previously Reported Enforcement Items Not inspected.
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Manacement Interview An exit management interviev was beld on site on February 27, 1976.
Persons in Att 2ndance at Exit Interviev
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Mr. R. Fenti, GPUSC Mr. S. Kakarla, UE&C Start-Up Mr. M. Nelson, CPUSC Mr. S. Poje, CPUSC hr. R. Toole, JUSC Mr. H. Ca n t er, MNFC
'Mr. A. Tasano, UShTC
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Items Discussed at Exit Inter-riev A
Additions to Table 14.1-1 in the FSAR, Details 3.
3.
Storage of Code Safety 7alves, Details 13.
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Test Equipment Controls, Details 9.
D.
Test Procedure verification, Det. ails 12.
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E.
Request for Licensee Documents, Detail's 15.
F.
Turbine Trip from 40%, Details 11.
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Item of Interest, Details 14.
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DETAILS
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1.
Persons Contacted Mr. J. Barton, Start-up & Testing Manager, CPU Start-up Mr. L. Briggs, Instrument & Control Engineer, B&R Mr. R. Carlson, I&C Test Engineer, UE&C Start-up Mr. J. Carraba, Construction QC Supervisor, UE&C Construction Mr. R. Fenti, GPUSC Mr. J. Floyd, Supervisor of Operation, TMI - 2 Mr. S. Kakarla, QC Supervisor, UE&C Start-up Mr. R. Lintr, I&C Instru=ent Control, GPU Mr. F. Mikolajesyk, I&C Assistant Instrument Supervisor, UE&C Construction Mr. M. A. Nelson, Technical Engineer, GPU Mr. S. G. Poje, Primary Plant Senior Engineer, GPU Mr. O. Rhyne, Mechanical Test Lead, UE&C Start-up Mr. E. Scmdall, Instru=ent Supervisor, UE&C Construction Mr. 1. J. Toole, Test Superintendent, GPU 2.
Purpose of Inspection This inspection was directed at the review of the administrative documentation for the establish =ent and control of a preoperational test program.
A secondary inspection effort included a tour of the facility and a review of procedures for consistency of procedure objectives with test titles.
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Test Program Reference FSAR Chapter 14; Test Instruction 18; Test Procedure Documents; Master Test Index; Generic Procedure TP 250/4, General Proceduta for Cleaning and Flushing Systems and Components; and, TP 250/2, Te ing and Checking of Mechanical and Electrical Equipment.
The program as described in the overall Test Plan, TMI Manual -
Rev. 4, October 27, 1975 provides policies, procedures and instruc-tions for administrative control of the test progran.
It also addresses require =ents to assure i=plemenration of the program.
The test organization and their responsibilities are described.
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-5-The specific references address flushing and cleaning of systems
and co=ponents, hydrostatic tests and instrument calibration.
Test Instruction 5, System Turnover, Rev. 1, 5/30/75 addresses the
transfer of systems or partial systems from construction to the
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licensee.
Test Instruction 18 addresses the requirement for functional demonstration of equipment in the various modes of operating The Master Test List includes ~the titles of each specific ranges.
test required to be perf ormed.
Test Instruction 13, Test Interface Instruction, further delineates requirements for electrical and mechanical testing.
The inspector reviewed the FSAR Table 14.1-1, Safety Related Tests Perfor=ed During Preoperational and Initial Start-up Test Phases.
In the inspector's review to verify that the applicant's test program includes require =ents for testing consistent with FSAR c d t=ents, two items of concern vere noted:
a.
76-03-1: Addition of TP 160/1 to FSAR Table TP 160/1, Hydrogen Reco=biner Test was not incuded in FSAR Table 14.1-1.
This test is a Category "A" Test. The licensee stated that this was an oversight and that the FSAR will be amended to include IP 160/1 in Table 14.1-1.
This item is unresolved pending the FSAR change; and, b.
76-03-2: Addition of TP 380/1 to FSAR Table
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TF 380/1, Cc==unications System Functional Test was labeled in the Master Test Index, MIX, as a Class 3 Test and not included in the FSAR, Table 14.1-1.
The inspector sited exa=ples which would indicate that this test is a Category "A",
Class 2 test.
One example cited by the inspector dealt with the i=portance of ce==unications during a fire which involves many people and much confusion.
Also, the coc=unications system uses reliable AC and DC power sources which therefore adds to the safety classification of this system.
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-6-i The licensee changed TF 380/1 to a Class 2, Category A test while the inspector was on site.
The licensee coe=itted to adding TP 380/1 to FSAR Table 14.1-1.
This item is unresolved pending the FSAR change.
Test Instruction 18 and the Test Plan addresses the format require-nent for the test procedures.
Test procedures contain objectives, prerequisites, and acceptance criteria.
The Test Plan has pro-visions for describing the scope of each test which is considered as a s m ry.
4.
Test Organization Reference FSAR Appendix 143; Test Instruction 14, Training and Qualifications of GPUSC start-up and Test Personnel, Rev. 3, 2/16/76; Test Instruction 9, Conduct of Test, Rev. 2, 12/4/74; Test Instruction 2, Test Plan, Rev. 2, 5/1/75; and, Test Instruction 13, Test Interface Instruction, Rev. O, 7/30/75.
The Test Plan addresses the qualifications and responsibilities of the key personnel in the preoperational program.
The Plan addresses means for assigning responsibilities and delineates the lines of authority between personnel and organizations.
The interface between organizations is addressed.
The inspector had no questions in this area at this M me.
5.
Test Procram Mministration Reference FSAR Appendix 14B; Test Instruction (TI) 2, Test Plan;/TI 5, System Turn Over; TI 7, Problem Report; TI 10, Prerequisite
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List; TI 1, Repair Removal Authorization, Rev. 2, 4/25/74; TI 9, Conduct of Test; TI 17, Shife Test Engineers I.og; TI 18, Test Procedure Documents; TI 3, Briefing and Dry Run, Rev. 3. 11/8/73; TI 6, Problem Report, Rev. 5, 3/28/74; TI 8, Unusual occurrence, Rev. 6, 5/1/75; TI 13, Test Interfact Instructions; TI 4, control of Test Records; and, TI 11, Test Index and the Test Change Notice.
The licensee's Test Plan provides for for=al methods for the test organization to receive frem other organizations the jurisdiction over systems, cceponents and instru=entation prior to :c==encement of testing.
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Formal ad=inistrative measures have been established for jurisdic-tional control of system, component or instru=entation status before, during, and subsequent to testing.
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Formal ad=inistrative measures have been established governing the conduct of testing including:
Methods for verifying that a test procedure is current prior a.
to use.
b.
Methods to assure that personnel involved in the conduct of a test are knowledgeable of the test procedure.
Methods to change test procedures during the conduct of c.
testing.
d.
Criteria for interruption of a test and continuation of an interrupted test.
e.
Methods to coordinate the conduct of testing.
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Methods to docu=ent significant events, unusual conditions or interruptions of testing, g.
Methods for identifying deficiencies; documenting resolutions and documenting retesting.
The docu=ent review and discussions with licensee personnel indicate that for=al methods have been established to control test activities.
A formal program has been established for the evaluation of test, results which provides for the following:
a.
Test data recorded in understandable form.
b.
Test data checks.co compare results to performance standards or limits.
c.
Deficiency notatien with actions specified for corrections.
d.
Tests or portions of tests to be rerun following corrective actions.
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Review of results by appropriate licensee personnel and contractors including persons or organizations involved in the g
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approval of the original test procedures.
The inspector had no questions in this area at this time.
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6.
Document Control
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T1 7, CPU Start-up Problem Report; TI 9, Conduct of Test; TI 18, Test Procedure Documents; ECM, Engineering Change Me=o; and, PCN,
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Project Change Notice cover measures that have been established which control the test procedure processes for review, approval, issuance, and revision.
In some cases, operating procedures vill be used, either whole or in part, for perfor=ance of preoperational tests.
In accordance with the Test Manual, all such operating procedures vill be POPC reviewed prior to use.
An aperture card file is maintained as a master index for drawings and =anuals which indicate their current revision nu=bers.
The ECM and PCN provide a mechanism which atte= pts to ensure that affected test procedures will be updated when manual or drawing revisions occur.
The inspector had no further questions on this item.
7.
Design Changes and Modifications The inspector determined that a for=al method has been established for initiating, reviewing and approving requests for design changes and modifications to equipment that has been turned over to the test group for preoperational testing.
A document entitled The FQ (Field Questionnaire) establishes a method by which the start-up organization can ask technical questions of the AE and obtain ansvers to these questions.
It also provid'es a mechanism for the start-up organization to' propose or to request a change of the design provided by the AE.
Another docu=ent entitled The FCR (Field Change Request) provides a method to accomplish major changes that have been properly reviewed, approved and documented to systems that have been turned over to the Field Start-up and Test Group, vendor assembled equipment and'
systems delivered to the construction site, and vendor changes to vendor supplie,d equipment.
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When changes to the FSAR and/or proposed Technical Specifications are necessary, the ECM, Engineering Change Memo and/or the PCI, Plant Change Notice is generat.ed to account for and track those s
changes.
The inspector verified that written administrative controls have been established for controlling temporary modifications, ju=pers,
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and mechanical bypasses. Administrative Procedure 1013, Bypass of
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Satety Features and Jumper Control, is the controlling docu=ent in
This document addresses the use of the jumper log and this area.
assigns the responsibility for maintaining the log by operations
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Instal k u ju=pers or lifted leads are addressed in the personnel.
to color and tagging of ju=pers.
document with respect The inspector had no further questions on this area.
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Equipment Protection and Cleanliness 8.
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The inspector verified that a program for housekeeping during II 19, Cleanliness of preoperational testing has been established.
and Systems and OSHA, Part 19.6, Section 2 Calibration Equipment are two of the formal docu=ents which are apparently followed as verified by direct observation in the plant.
An in-house auditor verifies periodically that OSHA requirements are met.
Docu=ents were verified to exist for the control of the licensee's program for maintaining cleanliness of nuclear plant components and piping during preoperational testing, including water chenistry controls for fluid systems undergoing preoperational testing.
These documents include TP 250/4, General Procedure for Cleaning and Flushing Systems and Co=ponents; TI 18, Test Procedure Docu-
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ments; and, MP 2/3, Individual System Flush Data Package (Partial).
The inspector had no questions on this item at this ti=e.
9.
Test and Measurement Ecuipment Reference TI 19, Control of Test Equipment, Rev. 1, 8/24/73.
The licensee has documented control measures of all instruments 'a test ceasuring equipment used during the preoperational and start-The instruction makes reference to Quality up tests for TMI.
Control procedures for the implementation of specific controls related to calibration, storage and issuance of =casurement equipnent.
The licensee's program includes direction for the controlled list,
The interface with proper use of measurement equip =ent of equipment.
is acco=plished by test procedure ref erences to the Master Test Equipment List, MTE.
The program includes the use of identifying tags to be affixed to the equipment showing calibration date and due date.
the on site calibration building for instruments used in
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Storage at construction and preoperational tests were observed by the inspector.
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The building was being controlled for humidity and te=perature.
Locks were marked and used for specific =casurement equipment.
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A selection of 4 pieces of equipment was chosen to account for controls of equipment in the field.
The following pieces were chosen:
Multimeter E97 Date due for calibration 3/4/76 Hydro =eter HD7 Date due for calibration 3/4/76 Therscreter 316 Date due for calibration 3/4/76 Pressure Gauge 25 2 Data due to calibration 3/10/76 Three of the above pieces were traced and located.
Each piece was checked fer calibration dates and found to be satisfactory.
The multimeter was not located.
It appears that sign out sheets and return sheets were lacking.
The licensee acknowledged that in-out-in records were lacking and that specific storage areas other than 2 cabinets were not specified.
The controls did not appear to be performed in the field in accordance with Procedure QC-13-2 which deals with test equipment storage.
This is an unresolved item (76-03-3) pending corrections in documen-
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tation (development and use of log) and storage to assure control of measurement equipment in the field.
10.
Training Reference Test Instruction 14, Training and Qualification of GPUSC Start-up and Test Personnel, key. 3, 2/6/76.
The main emphasis of the program is toward system co= prehension.
The instruction does require review and comprehension of the Test Instructions.
A thorough knowledge of the Test Instructions assures program understanding of the following areas:
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Test procedure preparation.
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Test procedure approval.
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Test performance and documentation.
d.
Test results review and approval.
e, Administative controls for testing.
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QA/QC for testing.
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Technical obj ectives.
The formal program has not been started.
A review of the implemented program records and verification of personnel knowledge vill be performed during a subsequent inspection.
This ite=i (76-03-4) vill be followed up af ter the satisfactory i=plementation of the program.
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i 11. Turbine Trio frora 40% Power Regulatory Guide 1.68 - November 1973, Appendix A, Section D.h
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states that a Turbine Trip (100%) Test is applicable to pressurized
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vater reacters.
Contrary to this regulatory guide, the licensee has chosen to perform the trip at 40% to provide base line transient plant response data.
The licensee stated that the generator trip from 100% in effect gives the same plant response as the turbine trip at 100%; therefore, since the generator trip vill cause a reactor trip due to high pressure, the licensee stated that it is not beneficial from a material or fuel standpoint to trip the plant from 100". power when not necesssry.
NRC staff meetings with the licensee and his contractors have concurred with the licensee position which was initiated in Ques-tion 413.1, Item 9e in the FSAR.
The inspector had no further questions on this item.
12.
Test Procedure Verification The inspector verified that the licensee has the following procedures written, reviewed, and approved, and that the test objectives are consistent with the test titles.
The objective of this verification is to review the scope of the licensee's test program to verify that adequate testing is planned to satisfy regulatory guidance a..I licensee cornitments.
The test procedure verification phase of IE's preoperational program is an ongoing ef fort conducted prior to the issuance of an operating license. This item vill, therefore, be followed up during future precperational inspections.
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TP*
MTX**
Title Approval Date***
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175/2 156.6 River Water Pu=p Ecuse
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Ventiletion 12/4/75 j
203/1 47.8 Borated Water Storage Tank 1/15/76 203/4 47.9 Decay Heat Re= oval System 1/29/76 203/7 47.10 Decay Heat Removal System S.F.
1/29/76 235/1 143.6 Reactor Building Sump Test 8/21/75 266/4 111.6 Nuclear Service River Water System 2/12/76 267/4 110.6 Nuclear Service Closed Cooling Water System 12/18/75 301/3A 108.2 Nuclear Instrumentation Pre-Op Calibration (Source Range)
2/26/76 301/3B 108.3 Nuclear Instrumentation Pre-Op Calibration (Int. Range)
2/26/76 380/1 219.25 Coc=unications System 2/26/76
Test Procedure Nu=ber (Category A Tests)
Master Text Index Nu=ber
Preliminary Review Meeting Minutes Date It is i=portant to note that the Office of Inspection and Enforcement (IE) preoperational inspection program deals with, a=ong other things, safety related tests.
FSAR Table 14.1-1 lists all Category
"A" Tests.
Category "A'" Tests are defined by the licensee as those tests which prove the SAFETY function of a system.
The Category
"A" Tests may also have two safety related classifications.
The two safety classifications as defined by the licensee are as follows:
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Classification 1 - System with safety related function only -
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consists of those systems which may or may not be operating during normal plant operation, but must be in constant readiness to perform their safety function (e.g., core flooding system);
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and, b.
Classification 2 - System with both safety related and non-safety related functions - consists of those systems which are normally in operation to provide a plant support function and are also required to operate during an e=ergency (e.g., Makeup and Purification System and Co==unications System).
t Therefore, the Test Procedure Verification phase of the IE pre-operational inspection program will be concerned with Class 1 and 2, Category A test procedures.
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Storage of code Safety Valves i
Regulatory Guide 1.68 - Nove=ber 1973 entitled, Preoperational and
Initial Start-up Test Programs for Water-Cooled Power Reactors addresses testing.of safety valves in Appendix A, Section A.l.b. (5).
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The guide calls for appropriate tests of these valves.
The licensee interprets the manuf acturers bench testing to be the appropriate preoperational testing on the two code pressuriser safeties even though this testing is done about 3 years pritr to installation.
The licensee received their safeties for storage on 2-6-74 according to QC release documentation.
The safeties are wrapped in polyethylene and stored in wood crates in a warehouse.
The licensee plans to perform no tests to verify their proper
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Periodic tests are planned during i
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refueling outages.
It is not clear, at this point, whether the length of storage time from manufacturers bench testing until installation vill change the set points of the safeties and hence invalidate the original tests.
This ites is unresolved (76-03-5) pending further evaluation by the inspector.
14.
Ite=s of Interest The inspector asked for the post core accident flood level in a.
the contain=ent su=p.
The level was given as 5.1 feet above the floor level at elevation 282.6 feet.
The inspector stated that the licensee may be asked in the future to evaluate if any safety related valves, pu=ps, or motors would become inoperative due to the water level in the su=p during a D.B.. A.
The licensee vill deter =ine if Three Mile Island - 2 has investigated this item.
The inspector had no further co==ents on this item.
b.
Ocornee 1 has been given by the licensee as the vibration prototype plant as per Regulatory Guide 1.20 - June 1975. The licensee's response to the inspector's question on what category IMI-2 fits into was that they apparently fall into the Non-Prototype Category I area as defined on Page 1.20-2 in R.G. 1.20.
The question arose as to why the Instru=ent Air (IA) System is c.
not a safety related Category A system.
The licensee stated that all Instrument Air Valves are designed to fail in the
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safe direction.
The LA piping system is designed as seismic Class II.
Power to the IA Systes cones from 460 volt non-essential buses nor= ally.
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Page 9.3-3 in the FSAR states, "Neither the Instrument Air or the Service Air System are required for a LOCA emergency or
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The IA System will be functionally tested i
during the preoperational test program.
The inspector had no further questions on this item.
15.
Recuest for Liter.see Documents The inspector stated that he vill officially request that all preoperaticnal start-up procedures listed in the Master Test Index (MTX) and categorized as Category "A" be sent on loan to the regional office for future review and reference.
The inspector stated that he vill request specific system descriptions for reference purposes.
The inspector was supplied an Index to Systems Descriptions and a vendor Training Manual at the conclusion of the inspection.
There were no questions on this item.
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