IR 05000320/1980011
| ML19345E969 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/25/1980 |
| From: | Conte R, Fasano A, Kottan J, Shanbaky M, Thonus L, Varela A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19345E953 | List: |
| References | |
| 50-320-80-11, NUDOCS 8102060477 | |
| Download: ML19345E969 (19) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
50-320/80-11 Docket No.
50-320 License No. DPP,-73 Priority Category c
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i.icensee:
Metropolitan Edison Company 100 Interpace Parkway Parsippany, New Jersey 07054 Facility Name:
Three Mile Island Nuclear Station Unit 2 Inspection at: Middletown, Pennsylvania Inspection conducted: June 1 - July 5, 1980 Inspectors: '2 M..I m 9 b 6!?C R. Co~nte, Senior Resident Inspector date signed M.Y gg/f/
9f/f //9hb M.
anbak Se i diation Specialist date signed L 'T L
10l2l80 A-
A. Varela, Rea tor Inspector date signed
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d J', Radiation Specialist 1012.l2O J. Kottan dat6 signed 4A?k da/o L. Thonus, Radiation Specia. list date signed r
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Approved by:
A. Fasano, Chief, Site Operations Section date signed TMI Program Office Inspection Summary:
Inspection on June 1 - July 5, 1980, (Report No. 50-320/80-11).
Areas Inspected:
Routine inspection by resident and regional based inspectors of selected new and revised procedures submitted for approval; procedure implementation; posting of notices to workers; shift manning / fire brigade composition; offshift operations activities; licensee measured reactor building concentration utilizing NRC (Region I) mobile laboratory; training program for reactor building purge evolutions; PWST construction activities; solid waste staging construction activities; surveillance procedures including associated data; and radioactive material control.
The inspection included daily onsite staff coverage with selected backshift coverage involving 218 inspector-hours.
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Results: Of the eleven areas inspected, five items of noncompliance were identified in three areas (Infractions - failure to properly implement the reactor building purge procedures, paragraph 3.b(1); failure to utilize the work request system to conduct safety related maintenance, paragraph 3.b(2);
failure to assure contaminated material is not released to uncontaminated areas; paragraph 8; Deficiencies - failure to submit a procedure revision to the NRC for approval, paragraph 3.b(3); failure to properly post notices to workers in accordance with 10 CFR 19.11, paragraph 4.c).
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DETAILS 1.
Persons Contacted R. Arnold, Senior Vice President
- B. Ballard, Sr., Quality Assurance (QA)/0perations Manager)
- J. Barton, Manager, Site Operations
- R. Bensel, Plant Operations Review Committee (PORC), Vice. Chairman
- D. Carl, PORC Administrator
- S. Chaplin, Licensing Engineer
- J. Chwastyk, Supervisor of Operations
- R. Fenti, Site QA Audit Supervisor G. Hovey, Director, TMI-2
- L. King, Manager of Operations
- S. Levin, Maintenance Manager
- H. Manning, Unit 2 Project QA Engineer
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Other members of the operations, health physics and administrative staffs were also interviewed.
- denotes those present at the exit interview.
2.
Facility Procedures Submitted for Approval Facility procedures and subsequent revisions, required to be submitted for approval to the NRC as required by the Order of February 11,1980, (Attachment 1 - proposed Technical Specification 6.8.2), were reviewed by the NRC TMI Program Office staff.
These procedures address the Recovery Operations Plan Implementation (Surveillance Procedures) and Recovery Mode Implementation (Operating Procedures).
Detailed review of selected procedures included both health physics and operations aspects with consideration of the following:
(1)
the procedures, when implemented, would not degrade the containment of radioactive material, jeopardize core cooling, or result in excessive personnel exposures; (2) the technical content of the procedures are adequate to perform the intended evolution.
Composite staff connents on procedures were forwarded to the licensee.
Licensee resolution of these comments was acceptable.
3.
Procedure Implementation a.
Implementation of selected portions of the following procedures was observed to verify compliance with specific procedural requirements and with established administrative controls for procedure usage:
Special Operating Procedure (SOP) R-2-80-40, dated
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June 25, 1980, Dry Run of the Procedure for Reactor -
Building Atmosphere Cleanup using the Modified Hydrogen Control System and the "B" Train of the Modified Reactor Building Purge System; and,
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Operating Procedure (0P) 2104-4.82, Revision 0, June 29, 1980,
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Reactor Building Atmosphere Cleanup using the Modified Hydrogen Control System and the "B" Train of the Modified Reactor Building Purge System.
In addition, selected portions of OP 2104-4.82 (referenced above) were reviewed for adequacy from a human factors /
engineering point of view.
b.
During this review, the below listed apparent items of non-compliance were identified.
(1) Special operating procedure SOP-R-2-80-40, dated June 25. M80, Dry Run of the Procedure for Reactor Building Atmosphere Cleanup using the Modified Hydrogen Control System and the "B" Train of the Modified Reactor Building Purge System was not properly implemented as follows.
On June 25, 1980, during the implementation of
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S0?-R-2-80-40, manual isolation valves (FS-V422B, 423B and 4248) for the reactor building ventilation and hydrogen control exhaust filter fire protection system were in the shut position.
This was contrary to S0P R-2-80-40, pre-requisite 4.25 which required that these valves be open by reference to the Fire Protection System Operating Procedure (2104-6.1).
Operating Procedure 2104-4.82, Revision 0, June 29, 1980, Reactor Building Atmosphere Cleanup using the Modified Hydrogen Control System and the "B" Train of the Modified Reactor Building Purge System, was not properly implemented as follows.
On July 1,1980, for approximately 20 minutes,
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AH-V3A, Containment Isolation Valve for the Modified Hydrogen Control (MHC) System, was left open on a " temporary shutdown" of the system.
This was contrary to the OP 2104-4.82 paragraph 5.4.2 which req; ired that this valve be shut on a
"temporarf shutdown" of the MIC System.
In addition on July 3,1980, for approximately-
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two hours, AH-V38, Containment Isolation Valve for Modified Hydrogen Control (MHC) System was left shut on startup of the MIC System. This was contrary to OP 2104-4.82, paragraph 5.2.10 which required that this valve be open to provide a return path for reactor building make-up air.
Reactor building negative pressure, with respect to atmospheric pressure, reached the procedural low limit at the time of the identification of this valve misalignment.
The purge was immediately secured by procedure.-
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The failure to implement facility procedures represents noncompliance (infraction level) with the Order dated July 20,1979, as amended by the Order dated Febraury ll,1980 (Attachment 1 - proposed Technical Specification 6.8.1.g)
and S0P R-2-80-40, paragraph 4.25 and OP 2104-4.82, paragraphs 5.2.10 and 5.4.2 (320/B0-11-01).
(2) On June 29, 1980, a contractor (vendor) individual worked on the Modified Hydrogen Control System exhaust fan while it was exhausting the reactor building atmosphere and no
" Work Request" form was completed for the job.
The nature of the work was to install a metallic covering over a section of the exhaust fan shaft to minimize suspected leakage between the fan shaft and struct;ral casing.
During the evolution, the individual caused the fan motor to trip on thermal overload (automatic shutdown).
No actual damage to the component resulted.
The work request form is required by Administrative Procedure (AP) 1026 to implement procedural requirements for the conduct of maintenance such as shift approval to perform work; procedural delineation; equipment / personnel safety measures; post-maintenance testing, etc.
As a result, these requirements were not implemented.
This represents noncompliance (infraction level) with the Order for Modification of License dated July 20, 1979, as amended by the Order dated February 11, 1980 (Attachment 1 -
proposed Technical Specification 6.8.1.a) and Regulatory Guide 1.33, Appendix A, and AP 1026 (320/80-11-02).
(3) The implementation problems noted above (paragraph 3.b(1)
and (2)) were discussed with licensee management on July 3,1980. At that time the licensee representatives indicated that a possible cause of these events could be due to several effective temporary changes to OP 2104-4.82 which could have caused operator confusion.
Subsequently, the licensee issued Revision 1 to permanently incorporate all temporary changes to OP 2104-4.82.
Between 4:00 p.m.,
July 3, 1980, and 8:00 a.m., July 4, 1980, Revision 1 was written, reviewed, approved and issued by the licensee utilizing the appropriate procadure processing system.
However, Revision 1 to OP 2104-4.82 was not approved by the NRC onsite staff which was required by Technical Specification 6.8.2.
Use of this procedure prior to the NRC approval.was noticed by the inspector at approxic3tely 9:00 a.m. on July 4,1980 and brought to the attention of the shift foreman.
Later that day the revision was formally presented to the NRC onsite staff inspector for review and NRC approval.
During initial cursory review
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by the NRC onsite staff inspector, it appeared the revision was a marked improvement over the previous version of OP 2104-4.82 and the onsite NRC TMI Program Office staff agreed to permit the licensee to use Revision 1 during NRC formal review and approval of the revision.
The failure to properly implement orocedures is addressed in paragraph 3.b(1) and (2).
The failure to submit Revision 1 of OP 2140-4.82 to the NRC for approval represents a noncompliance (deficiency level) with the Order dated July 20, 1979, as amended by the Order dated Febraury ll,1980, (attachment 1 - proposed Technical Specification 6.8.2)
(320/80-11-03).
The NRC onsite staff inspector noted that this was the first identified case since the March 28 accident where a procedure was not properly submitted to the NRC for apprc val.
Plant management discussed the item with the personnel involved.
The NRC onsite staff inspector considered the above corrective action adequate to preclude recurrence.
The inspector stated that this area will be reviewed during a subsequent inspection. There were no further comments in this area.
It appeared to the NRC onsite staff inspector that the above problems were, in part, due to the expeditious manner in which the licensee conducted the purging evolution.
As an additional example of this during the NRC review of Revision 1 on July 4,1980, it was noted that OP 2104-4.82, paragraph 5.24 referenced paragraph 5.2.6 for continuation of system startup procedural steps.
This procedural instruction could cause paragraph 5.2.5 to be missed which required the openning of valves AH-V5 and AH-V6 and aligns the reactor building pressure sensing instrument for high pressure shutdown of the exhau:t fans.
Since the valves were already properly aligned due to a previous system startup, this oversight did not cause an actual problem.
The licensee corrected this specific procedural item through a subsequent change to the procedure.
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c.
The fol' sowing matter was addressed to licensee management.
On l
June 2Js 1980, during the implementation of OP 2104-4.82, for
approximately one hour, valve AH-V5, Reactor Building Sensing
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Line Outer Isolation Valve, was shut to sample the reactor l
building atmosphere (separate procedure) at the 354 foot
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elevation.
However, this valve was supposed to be open to maintain the operability of the high pressure shutdown inter-lock for the reactor building purge exhaust fans.
It appeared to the NRC onsite staff inspector, during a review subsequent
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to this event, that no formal effort was made to resolve the l
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conflict between the sampling procedure and the operating procedure with respect to the interlock operability require-ments. Subsequently, the licensee did take corrective action by revising OP 2104-4.82 to permit the sampling at the 354 foot elevation with an additional precaution concerning continuous operator surveillance of reactor building pressure.
The inspector stated that the above precautionary actions should in the future be taken prior to implementation of a procedure.
It is preferred that the operating procedure be reviewed from a human factors / engineering point of view prior to approval. The licensee representative acknowledged the above and the NRC onsite staff inspectoe had no additional coments in this area.
4.
Posting of Notices to Workers a.
Requirements for the posting of notices to workers were reviewed to verify compliance with 10 CFR 19.11 and specifically the following items were verified:
Posting was accomplished for Part 19 and 20 regulations;
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the license conditions or documents incorporated into the license by reference and amendments thereto; the operating procedures applicable to licensed activities; (the above may be substituted by a notice which describes the document and states where it may be examined);
Posting was accomplished for any r.otice of violation
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involving radiological wrking conditions, proposed imposition of civil penalty or order issued pursuant to Subpart B of 10 CFR 2 and any licensee response; The required postings were in a sufficient number of
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places to permit individuals engaged in licensed activities to observe them on the way to and from the location of the activity to which the document applied; and, The required postings were to remain posted in accordance
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with 10 CFR 19.11(e).
b.
The following areas in Unit 2 were observed:
Control Room Bulletin Board;
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Health Physics Controi _ Point at the entrance to the
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auxiliary building; South gate entrance to Unit 2;
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Unit la2 interface gates; and,
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Search 2 (entrance to Unit 2 protected area).
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c.
One apparent item of noncompliance was identified.
As of June 30,1980, the requirements of 10 CFR 19.11(a)(4) and 10 CFR 19.ll(d) and (e) were not met in that:
tione of the orders issued, pursuant to Subpart B of
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10 CFR 2, since July 20, 1979, were posted; The riotice of Violation issued by the Office of Inspection
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and Enforcement (Region I) dated itay 28, 1980, was not posted in a sufficient number of p' aces, that is, it was pasted only on a bulletin board in the Unit 2 control rcom.
This flotice of Violation involved uncorrected radiological working conditions (licensee response to the items was not issued);
The Unit 2 control room is not a normal access to radiological areas such as the auxiliary building; and, The tiotice of Violation issued by the Office of Inspection
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and Enforcement, dated October 25, 1980, was not posted.
The associated civil penalty (on the f4 arch 23,1979, accident) was also not posted and contained certain uncorrected radiological working conditons.
The licensee's response to these items was not posted.
This represents noncompliance (deficiency level) with 10 CFR 19.11.a(a)
and 10 CFR 19.ll(d) and (e)
(320/80-11-04).
5.
f4f nimum Shift / Site Fire Brigade Composition a.
The ilRC onsite staff inspector reviewed licensee reccsis and interviewed personnel to verify compliance with minimJi shift / site fire brigade composition requirements of tM Order of July 20, 1979, as amended by the Order of February 11, 1980, (attachment 1 - proposed Technical 3pecification (TS) 6.2.2.d).
This required that the unit organization shall have five members assigned to the site fire brigade and the brigade shall not include three of four possible members from the minimum shift composition (T5 Table 6.2-1:
1 Senior Licensed Operator, 1 Licensed Operator, 2 tionlicensed Operators).
b.
The following records were reviewed:
Control Room Operator Log Sheets for the period
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flay 10-20, 1980; June 6-15, 1980 and July 8,1980, for all shifts; Effective shift scheduies issued June 2,1980;
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Shift attendance sheets for June 6-8, 1980; and,
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Control room operators'1og (narrative) for period
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llay 10-20,1980.
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c.
No items of noncomplicqce were identified, however, one unresolved item w 3 noted. The control room leg sheet had provisions for '.
ing personnel assigned to the fire brigade.
However, deline ;1on of those individuals assigned for plant control (minimum st'It composition) was lacking.
In several instances it appeared to the NRC onsite staff inspector that all quali
suxiliary operators were assigned fire brigade duties wn.iout at least one auxiliary operator for auxiliary plant control functions during a potential fire casualty.
Selected attendance sheet documentation supported the fact that additional qualified auxiliary operators were available on shift.
The licensee representative acknowledged the above finding and revised the log sheet to include the names of personnel assigned minimum shift composition duties.
This is unresolved pending NRC review of the effectiveness of the above measures (320/80-11-05).
6.
Offshift Operations Inspection a.
On June 9,1980, between 4:30 a.m. and 6:30 a.m. an operational review in the control room was conducted to verify the following:
Implementation of proper logkeeping requirements; and,
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Compliance with selected Limiting Conditions for Operation
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(LCO) per Order of July 20, 1979, as amended by Order of
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February 11,1980, (Attachment 1 - proposed Technical Specifications).
b.
The following documents were reviewed:
Shift foreman's (narrative) log for 11-7 shift;
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Control room operator's (narrative) log for 11-7 shift;
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Shift and daily check log for 11-7 shift; and,
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Control room operator's log sheet for 11-7 shift.
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c.
The following LC0's were verified (methoc of verification):
TS 3.8.1.1.a, Two independent offsite sources of power
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(observation);
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TS 3.4.1, Reactor Coolant System (RCS) operated in accordance
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with approved procedures (records review);
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TS 3.4.9.1, RCS Temperature <280'F and Pressure <600 psig
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(observation);
TS 3.7.4.1, Two independent nuclear services river water
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loops operable (in 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action statement time for one loop inoperable due to des 11 ting operations) (observation);
TS 3.7.7.1/4.7.7.1, Control Room Temperature <100 F
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(observation); and,
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TS 3.3.3.5 (Table 3.3-9) RL. let Temperature 1/ loop to
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remote shutdown panel (digital n.eter out of service in 30-L u action statenent) (record review).
No items of noncompliance were identified.
7.
NRC (Region I) Mobile Laboratory Activities The Region I Mobile Laboratory was used to compare analytical results of Kr-85 measurements of the Unit 2 containment building atmosphere. Measurements were made on June 5, 1980, using sampling containers supplied by the licensee.
These results are on Test Results Table 1 attached.
This is a sample geometry not nomally used by the NRC for counting gas samples. However, the sampie was counted as far from the detectors as possible (18 cm) to minimize this difference.
Note that the results are either in agreement or possible agreement.
Measurements were made on June 5 and 6, 1980, of samples taken in NRC geometries. These results are listed on Test Results Table 2.
This is not a geometry nomally used by the licensee. Note that the results are in agreement.
A more meaningful comparison would match the licensee's results using their nomal sample geometry against the NRC results using the fiRC nomal sample geometry. This, of course, assumes the sample source is homogeneous.
These results are listed on Test'
Results Table 3.
Note that the measurements are in agreement.
i The criteria used for comparing i...alytical measurements are l
those contained in the Office of Inspection and Enforcement !!anual
Procedure 847118. The flRC mobile laboratory was calibrated using a l
Kr-85 standard supplied by the National Bureau of Standards.
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TABLE 1
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8.
Contaminated Material Control In the time period June 20, 1980, through June 26, 1380, a number of items were released from the Unit 2 control point to clean areas by several health physics technicians.
These items included scaffolding tubes, piping, boards and other miscellaneous materials and equipment.
Criteria for release of the items varied from technician to technician and was, in some cases, not as stringent as required by the licensee's release criteria.
On June 26, 1980, a contaminated sign was found on a truckload of material being taken out gate 4.
This prompted a resurvey of the
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material outside the control point in that the sign had come from this area.
The truck with the remainder of the items was allowed to exit the restricted area and go to a storage area for the materials on the truck.
The resurvey disclosed that several contaminated items had been unconditionally released to clean (non-contaminated) areas.
These items were not labeled as being contaminated or containing radio-active materials. Maximum external contamination on one piece of pipe was greater than 10,000 dpm/100 cm2; maximum radiation levels on this piece of pipe were 10 mrad /hr.
The area containing these items was roped off and posted.
A health physics technician was dispatched to resurvey the balance of material on the truck which had left gate 4 and gone to the storage area. Surveys of this material disclosed three items contaminated above the licensee's release criteria.
The release of the contaminated items to uncontaminated areas without proper labeling and btgging (or other contamination control measures) represents noncompliance (infraction level) with the Order of July 20, 1979, as amended by Order of February 11, 1980, (Attachment 1 - proposed Technical Specification 6.8.1.f) and Unit 2 Health Physics procedure 1682, paragraph 5.1.1 (320/80-11-06).
9.
Licensee Training Program for Reactor Building Purge Evolutions From June 9-24, 1980, selected portions of the operator training
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program for reactor building purge evolutions were reviewed to l
ascertain the depth and quality of information presented to the operators and ascertain the level of knowledge of personnel in charge of the shift activities.
Observations were made in the following areas:
Reactor building purge operator and shift engineer classroom
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l training syllabus and qualification test;
Shift engineer classroom training and walk-through on June 11, 1980;
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Operator training session on June 14, 1980;
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Licensee conducted shift foreman interview on June 19, 1980;
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Selected qualification signoff records for the TMI-2 reactor
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building purge system; and, Selected portions of dry run testing conducted during the week
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of June 9,1980.
No items of noncompliance were identified.
10. Processed Water Storace Tanks (PWST) Construction Activities a.
Between June 16 and 19,1980, a review of construction aspects of the processed water storage tanks (PWST) w9s conducted.
The two PWSTs are 500,000 gallon radwaste liquid storage tanks for processed water.
Reference for this review was Engineering Change Memoranda (ECM) 545, 571, 650 and Memo #R-2527 of April 10,1980, G. Clements to R. Prabhaker which requested GPU QC activities on Soils, Foundations and Concrete work be performed by Catalytic forces.
Civil / structural recordt of 37 in-place Sand-Cone and
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Washington Densometer tests for tank #1 and #2 foundation and backfill were reviewed for conformance to criteria identified in Bechtel Spec C-234.
Concrete records for both tanks' mud mat and ring walls
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were reviewed for conformance to criteria identified in Bechtel Specs C-352 and C-338 and GPU QC Civil Procedure QCP-M-013.
Spec C-141 of Bechtel for tank erection criteria and PDM
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Field QC Manual of NDE Procedures and test criteria were reviewed.
Vacuum box testing on tank #1 bottom plates lap joint
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fillet welds was observed.
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b.
No items of noncompliance were identified.
However, it was noted that non-structural fill requires additional recompaction, after PDM tark erection is canplete (on exterior side of ring
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walls of both tanks).
The licensee representatives indicate that recompaction will be performed.
l In addition, it was noted that ECM #650 (task WG-24), dated
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May 16, 1980, on tank erection and testing is identified as
"QC No" as regards to GPU-QA classification.
However, based on discussion with the licensee's representatives GPU QA will provide verification that PDM's QC submissions on " Quality l
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Verification Document Requirements", (required by Bechtel Spec. C-141, Appendix B), are acceptable for turnover to Bechtel prior to completion of PDM work on the PWST Tanks No.1 and No. 2.
The inspector had no further canments in this a rea.
11. Solid Waste Storage Facilities a.
Civil / structural records pertr'
=] to Module A and B units for foundation preparation, muu mat installation, rebar, formwork, and concrete placement including material quali-fications, batch plant qualifications and operation and cercrete batching, mixing truck delivery, concrete testing and placing, and curing were reviewed for conformance to criteria established in the following:
GAI Spec 398-070;
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GAI drawings E-424-001, E-430-007 and E 744-151; and,
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GPU QC Procedure / Civil Construction Inspection QCP-M-013.
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Fifty-one daily inspection reports covering the period July 17,1979 through November 21, 1979, were observad indicating conformance to criteria established above.
Module D excavation, foundation proofrolling and testing was also observed.
b.
Some inspection reporte identified nonconforming items which were reviewed by engineering and appeared adequately resolved.
No items of noncompliance were identified.
12.
Surveillance Procedures a.
Selected surveillance prccedures were reviewed to verify the following:
Prerequisites and preparation for the test were specified;
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Acceptance criteria for the test were specified;
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Restoration to normal instructions of systems or components
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were delineated; and,
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The technical content was adequate to assure compliance with Technical Specifications (TS) requirements.
Completed test data were reviewed to verify the following:
Tests were conducted in conformance with TS and procedural
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requirements;
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Completed tests were reviewed as required by licensee
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administrative requirements; Tests were performed within the time frequencies specified
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by TS;
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Appropriate action was taken for any item failing acceptance
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criteria; and, Tests were performed 'i qualified individual (selected a
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personnel),
b.
The following surveillance procedures / completed test data (indicated by date) were reviewed:
Selected portions of Surveillance Procedure 4301-W1,
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Revision 0, November 28, 1979, Weekly Surveillance Checks (TCN No. 2-80-125, dated April 27,1980).
This was in reference to TS 4.1.1.1.1.1, SPC Tank total gas and boron concentration limits and to TS 4.1.3.1, Control
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Rod Drive Breakers open.
Data was neviewed for: April 11, 17, 24, May 15, 22, 29, June 5,12, and 19,1980.
Selected portions of Surveillance Procedure 3303-Al,
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Revision 5, October 8,1979, Fire System Valve Cycling.
This was in reference to TS 3.7.10.2.d and e/4.7.10.2, Fire System Deluge Isolation Valve, Reactor Building Ventilation System.
Data was reviewed for January 26 -
February 17, 1979 and February 2-4, 1980.
c.
No items of noncompliance were identified, however, two unresolved items wert disclosed.
(1)
During the review of data fcr surveillance procedure 3303-Al for Unit 2 valves, several incomplete exception and deficiency report forms were noted.
The forms were l
incomplete in that resolution of the exception / deficiency j
was not doccmented and signed off by the test coordinator.
Based on a review of AP 1010, Revision 16, May 21,1980, Technical Specification Surveillance Program, it was determined that exceptions on test data were for tests where noted problems did not effect the intent of the test procedure.
A deficiency was for failure to meet
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the test acceptance criteria.
For the data on February 2-4, 1980, eight exceptions were documented with no reso!ution and no test coordinator sign off of resolution complete.
In addition it appeared to the inspector that the operators who performed this-test were somewhat confused with respect to the classi-fication of discrepancies associated with completed test data.
In all of the eicht exceptions noted above, a l
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v
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+
+
t-g
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block was checked indicating the exception caused the surveillance to be unsatisfactory with regard to TS.
Inspector review of these exceptions revealed TS were not affected.
For example, certain valves couldn't be cycled due to their location being in the TMI-2 reactor building.
The reactor building was not entered, due to ALARA consideration, until July 1980 and the TS specifically exempted this type of case.
The inspector stated that it appeared additional training was needed in the use of the Exception / Deficiency form for corrective action.
In addition it was stated that the status of resolution of the above exceptions needed to be updated.
The licensee representative acknowledged the above and agreed to review this area.
This is unresolved pending completion of licensee action as stated above and subsequent NRC review (320/80-11-07).
(2)
During the above review, the inspector attempted to determine what records reflected valve position status for the plant in particular, for the fire system deluge isolaticns valves for the reactor building ventilation filters and more generically for all plant systems valves / breaker alignments.. It appeared that several administrative programs were in effect to secure and identify equipment in a controlled status.
The appendix lineups for system operating procedures reflect only a prestartup alignment for valves / breakers and the current systam alignment is dependent on the last section completed for the operating procedure.
Usually this is the " normal operating section" of the procedure.
The appendix lineups (latest) are kept in the control room for operator reference.
It was noted that the last lineup for the fire protection system operating procedure (OP 2104-6.1) was not in the control room files. The licensee representative indicated that since that system was last started on a system wide basis prior to the March 28, 1979, accident (on initial plant startup) the completed procedure was probably in the data reduction group (established for coordinating data fo; various review groups as a result of the accident).
Other system files did indicate the latest completed procedure in the control room file.
This procedural status system is supplemented by surveillance procedures which do provide information to check the operability of components such as valves and allow for the confirmation that these components are restored to a normal plant lineup.
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Control of equipment during maintenance is assured by use of a switching and tagging system.
This program assures the deenergization and isolation of equipment during maintenance / modification and specific written orders are utilized to control change of state of equipment during the various phases of maintenance.
The inspector stated that, based on the discrepancies of paragraph 12.c(1) above, this area is unresolved pending further review by the NRC to assure that these programs are effective in presenting a consolidated view of plant status for equipment in a controlled status (320/80-11-08).
13. Unresolved Items Unresolved items are findings about which more information is needed to ascertain whether it is an iten of noncompliance, a deviation, or acceptable. Unresolved items disclosed during this inspection are discussed in paragraphs 5.c and 12.c(1) and (2).
14. Exit Interview At periodic intervals during the course of this inspection, meetings were held with senior facility management to discuss inspection scope and findings.
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