IR 05000320/1980012
| ML20037D291 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/20/1980 |
| From: | Bores R, Conte R, Fasano A, Gallina C, Nicholas H, Sanders W, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20037D287 | List: |
| References | |
| 50-320-80-12, NUDOCS 8107090281 | |
| Download: ML20037D291 (13) | |
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U.S. NUCLEAR REGULATORY COMMlSSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
50-320/80-12 Docket No.
50-320 License No. DPR-73 Priority Category C
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Licensee:
_ Metropolitan Edison Company 100__Interpace Parkway Parsippany, New Jersey 07054 Three Mile Island Nuclear Station Unit 2 Facility Name: _
Inspection at:
Middletown, Pennsylvania Inspection conducted:
July 6 - August 31, 1980 and September 11-17, 1980
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Inspectors:
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R. Contei Senior Resident Inspector date signed M.$
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/0/$/10 M. 'Shanbaky, Senior Vdiation Specialist date signed hA' -
le/Nf90 Abdad t
C. Gallina Amergenc[ Planning Coordinator, Region I dat'e sfigned o-o
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C H. Nicholas, Reactor Inspector dats sitned Wl f f Art b /
/0l/o /0 W. Sand 3rs, Reac r Inspector dat'e signed Accompanied Dr Totes, T'e, U Wronmental and Special by:
Projec_ts S tion, FF&MS Branch
/d//9 NO date signed
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A.
sano, ChiFi
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h.Ke M Approved by:
~ Sit er rons Section, date signed I Program ice
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Inspection Summary:
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Inspection on_ July 6 - August 31, 1980 (Inspection Report No. 50-320/80-12)
Areas Inspected:
Routine inspection by resident and rejional based personnel oT licensee action on previous inspection findings; selected new and revised procedures; licensee procedure implemeatation; plant operations; health physics and environmental inspection ar.d review; emergency drill; construction aspects of submerged demineralizer system (SDS); preoperational aspects of mini decay heat (MDH) system; licensee event reports (LER-in office review).
The inspection involved 266 inspector hours by 5 NRC resident inspectors, and 23 inspector hours by 3 NRC regional based inspectors.
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i Results: Of the nine areas inspected, no items of noncompliance were identified, however, two deviations were identified in one area (Deviations - applicable welding specification not available at work location, Paragraph 8.b; no inprocess inspection activity was conducted on welding work activity, Paragraph 8.b.).
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DETAILS 1.
Persons Contacted General Public Utilities Nuclear Group (GPUNG)
R. Arnold, Chief Operating Executive
- J. Brasher, Manager Radiological Controls (Unit 2)
S. Chapman, Licensing Engineer (Unit 2)
- J. Chwastyk, Supervisor Plant Operations (Unit 2)
- R. Corbit, Welding Engineer
- T. Currie, Lead Quality Control Engineer
- E.
Fuller, Supervisor of Licensing (Unit 2)
- G. Giangi. TMI Emergency Planning Coordinator M. Heri Startup and Test Manager (Unit 2)
G. Hov.
Director TMI-2 A. King, Manager Operations (Unit 2)
- G. Kunder, Supervisor Compliance
- J. Renshaw, Manager Radiological Controls Field Operations (Unit 2)
J. Wright, Quality Control Manager Catalytic Incorporated
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R. Paterson, Welding Engineer NRC TMI Program Office R. Bellamy, Chief, Technical Support Section T. Poindexter, Systems Engineer Other members of the operations, radiological controls and administrative
staffs were also interviewed.
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l 2.
Licensee Action on Previous Inspection Findings
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(OPEN) Unresolved Item (320/80-01-01):
Correction of Material / Personnel I
Discrepancies Associated with Emergency Planning.
On August 7, 1980, a site emergency drill was observed and several repetitive deficiencies were noted.
Details are addressed in Paragraph 7.
3.
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, (Att h-ment 1 proposed Technical Specification 6.8.2), were reviewed by the dRC l
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TMI Program Office staff.
These procedures address the Recovery Operations Plan Implementation (Surveillance Procedures) and Recovery Mode Implementa-tion (Operating Procedures).
Detailed review of selected procedures included both health physics and operations aspects with consideration of the follow-ing:
(1) the procedures, when implemented, would not degrade the containment of radioactive material, ieopardize core cooling, or result in excessive personnel exposures; (2; the technical content of the procedures are adequate to perform the intended evolution.
Composite staff comments on precedures were forwarded to the licensee.
Licensee resolution of these comments was acceptable.
4.
Procedure Implementation Imrlementation of selected portions of the following procedure was observed co verify compliance with specific procedural requirements and with estab-lished administrative controls for procedure usage.
Implementation of operating procedure OP 2104-4.91, Revision 0, July 22, 1980, Reactor Build-ing Purge Using the Modified Purge System (TCN No. 2-80-284, oated August 4, 1980) was observed on August 22, 1980.
No items of noncompliance were identified.
5.
Plant Operations Review a.
On a periodic basis the resident inspector obtained information on plant conditions, reviewed selected plant parameters for abnormal trends, ascertained plant status from maintenance / modification view-point, and assessed logkeeping practices in accordance with administra-tive controls.
During the review the resident inspector made random visits to the control room during regular and back shift hours, discussed operations with control room personnel, reviewed selected control room logs and records and observed sclected licensee plan of the day meetings.
b.
During this review, no items of noncompliance were identified, however, one unresolved item was noted.
During the week of August 25, 1980, one of four auxiliary building exhaust fans (designated AH-E-88) was made inoperable for corrective maintenance.
This necessitated shifting operation to another pair of fans (8C and 8D).
Two exhaust trains exist with two fans per train.
Ex5aust trains and fan pairs can be cross-connected.
Technical Specification (TS) 3.9.12 requires that the " fuel handling building / auxiliary building" air cleanup system be operable with exhaust flow through the HEPA filters.
The associated surveillance requirement to prove operability of the exhaust fans specifies an
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exhaust flow of 63,000 + 105cfm with a pressure drop of <6"H,0 across the exhaust filter trains.
When the 8C and 8D fans were opePated, only 56,000 cfm air flow was achieved.
The system was declared inoper-able.
After 7 days without the air cleanup system restored to normal the licensee suspended liquid and gaseous movement in accordance with TS 3.9.12.
During this review it was dete rmined that TS 3.9.12 needed clarifica-tion with respect to what fan / exhaust filter 1r in combinations were considered redundant subsysteus within each bu.1 ding air cleanup system; and with respect to stparately addressing the fuel handling building and auxiliary building air cleanup system to preclude iuproper implications that one building system is redundant :o the other building system.
With respect to the above event the resident inspector stated that since redundant trains, pairs of fans were not addressed in the TS, the flow specification of the surveillance requirements must be applied whenever there is knowledge that the surveillance test con-dition/ criteria could not be met.
The licensee acknowledged the above and agreed to submit a TS change addressing this area.
This is unresolved pending completion of action by the licensee as stated above and subsequent review by the NRC (320/80-12-01).
6.
Health Physics and Environmental Inspection and Review a.
Plant Tours Shift inspectors completed a general plant inspection tour daily.
These inspections included all control points and selected radi)1og-ically controlled areas.
Observations included:
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Access control to radiologically controlled areas;
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Adherence to Radiation Work Permit (RWP) requirements; Proper use of respiratory protection equipment;
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Adherence to Health Physics and Operating Procedures;
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Use of survey meters including personnel frisking techniques;
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Cleanliness and housekeeping conditions; and,
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Fire Protection measures.
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b.
Measurement Verifications Measurements were independently'obtained by the NRC onsite inspectors to verify the quality of licensee performance in the following selected areas:
Radioactive material shipping;
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Radiological control, radiation and contamination surveys; and,
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Onsit6 environmental air samples.
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No items of noncompliance were identified.
7.
Emergency Drill Observations a.
A Unit 2 emergency drill was observed on August 7, 1980, by inspectors from the NRC TMI Program Office staff and NRC Region I in order to verify the following:
Organizational response was coordinated, orderly and timely;
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Immediate and supplemental actions of the applicable emergency procedures were properly implemented; Adequacy of health physics practices, radiological dose assessment
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and utilization of emergency response kits for radiological emergencies;
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Adequacy of internal communication systems and techniques;
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Licensee use of " drill observers" to identify and evaluate " drill participants" response and the adequacy of drill observer comments; and, Corrective actions initiated by the licensee to conduct drill
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identified deficiencies.
b.
The drill scenario involved a standby pressure control (SPC) system line break.
A pre-drill briefing was conducted for all licensee and NRC observers by the Supervisor of Technical Specification Compliance.
All initial conditions were reviewed as well as a detailed sequence of events for the postulated accident, including simulated data for the course of the event.
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c.
Several deficiencies were identified during the above referenced drill.
Some of the deficiencies identified had been noted during l
earlier drills, documented in Office of Inspection and Enforcement l
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Report No. 50-320/80-01 and included as an unresolved item (320/80-01-01)
pending completion of action by the licensee and subsequent review by the NRC.
These deficiencies included the following general areas:
Audibility of alarm system;
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Qualifications of individuals manning responsible positions;
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Use of administrative aids including the use of check lists and
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status boards; Rapid dose assessment capability; and,
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Familiarity with emergency equipment.
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d.
The NRC also noted that the licensees overall ability to identify, document, eve.luate and correct drill-identified deficiencies was inadequate in the following areas:
A significant discrepancy existed between the number of drill
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identified deficiencies noted by the NRC compared to those noted by licensee observers; Licensee identified items documented on drill critique sheets
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were not adequately evaluated and consequently were not identified for subsequent corrective actions; and, An adequate tracking mechanism to determine the status for the
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correction of drill-identified deficiencies was not in place for Unit 2.
e.
The licensee and NRC drill observers identified deficiencies in the licensee's emergency response capability in the following areas (NOTE:
Licensee identified actions based on memorandum by J. J. Barton, dated August 11, 1980, on this subject):
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Accurate source term could not be determined during the course of l
the drill; Interface and coordination problems developed with offsite licensee
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environmental personnel; and, Communication problems within the control room between operational
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and radiological assessment groups (improper location of phones, such as Health Physics Network (HPN) circuit used in an adjacent room to the control room where the Emergency Director (ED) is located.
It appeared that the ED was not knowledgeable of infor-mation flow on that circuit).
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In addition, NRC observers identified deficiencies in the licensee's emergency response capability in the following areas:
Emergency implementation procedures were not used in a timely or
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effective manner during the drill (e.g., procedures in the control room were not referred to until 30 minutes into the drill);
Emergency implementation procedures had not been updated to
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accurately reflect the existing types, locations and uses of facilities and equipment at Unit 2 (e.g., existence and location of Operations Support Center and Technical Support Center);
Action levels as contained in the emergency implementation pro-
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cedures had not been updated to accurately reflect currently instr.lled instrumentation reflective of ongoing recovery operations at the Unit 2 site (e.g., EPICOR-II effluent monitors);
Emergency duties were not clearly defined nor was the interface
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with Unit 1 adequately demonstrated; Licensee personnel did not demonstrate adequate proficiency in
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the use of onsite alarm equipment, telephone notification pro-cedures and sampling equipment; Health physics supervisors were not informed of the drill events
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and conditions in a timely manner (e.g., they were not informed of the event until 30 minutes into the drill);
Status boards in the control room and at the health physics
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control point were not effectively utilized (e.g., certain radio-logical information did not appear on the boards until 15 minutes after it was known in the control room);
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Air sampling equipment noise in the control room interfered with emergency response communications in that area; An adequate number of Scott Air Packs were not available for
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emergency operations at the time of the drill; Decontamination showers were inoperable at the time of the drill;
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Evacuation alarms were not audible in certain locations; and,
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Unified records of operator actions were not maintained.
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t g.
Following a detailed review and evaluation by the NRC of the perform-ance of the emergency drill, a meeting was held with licensee repre-sentatives on September 11, 1980, in order to discuss various aspects
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of the licensee's overall emergency preparedness capability.
Subsequent to this meeting, an immediate action letter was issued to the licensee on September 17, 1980, documenting the NRC's understanding of the licensee's committments to upgrade the emergency preparedness capability at the TMI Unit 2 site.
Unresolved item 320/80-01-01 will remain open pending the NRC review of licensee actions as delineated in the afore-mentioned letter.
8.
Submerged Demineralizer System a.
General
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Two walk through inspections were made to inspect the activities in progress on the installation of the piping and equipment for the submerged demineralizer system in the Unit 2 spent fuel pool.
Particu-lar attention was given to the filter manifold where a welding opera-tion was in progress using the tungsten inert gas (TIG) welding process.
The welding in progress appeared to be of good quality as judged from the outer appearance of the weld bead, crown height, and the merging of the weld metal to the base material.
Other miscellaneous sub-assemblies and pipe pieces were visually inspected.
Visual inspections were also made of the feed tank system, associated piping and valving and structual supports relative to the two parallel primary ion exchange t"ains for the zeolite media and the two parallel ion exchange beds containing organic cation resin.
The following documentation was reviewed:
Technical evaluation report;
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Welder qualification, 4 welders;
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Weld Procedure Specification (WPS) SP-4200-SS(N)-101A;
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Quali~? cation. record for above;
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Installation procedure 2300-IN-015;
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Drawings for Shipping Cask Support Platform; Drawing 527-D-M-5023-0;
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Engineering specification for piping 3064 A 81;
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GPU audit of Chem Nuclear Systems Incorporated (CNSI) audit
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activities; and, i
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Installation procedure 2300-IN-015 for the SDS feed manifold
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assembly.
b.
Inspection Program for Pipe Welding The technical evaluation report for the submerged demineralizer system paragraph 4.3.6 requires that the mechanical cnd structural design criteria and the fabrication of piping systems and piping components are to meet requirements as specified in Regulatory Guide 1.143 and ANSI B31.1, 1977 edition through the winter 1978 edition.
The edition of the code states that the welding processes to be used shall meet all the test requirements of Section IX of the ASME Boiler and Pressure Vessel Code.
The system constructor is using WPS SP-4200-SS(N)-101A which has been qualified to the requirements of ASME Section IX.
The WPS states that any deviations from this specification shall be documented and approved with an engineering design change notice. The WPS defines certain quality characteristics listed below.
Concavity limits on the root side of a s:ngle welded circumferented
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butt weld;
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The removal of arc strikes and follow up nondestructive examination (NDE);
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The cleaning and preparation of weld joints; Fit up and alignment requirements;
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l Welding gas purity;
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Backing gas flow rates;
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Butt weld joint maximum offset;
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Maximum and minimum tolerance on weld gap opening; and,
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Interpass temperature.
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The. inspector noted that the applicable WPS SP-4200-SS(N)-101A was not l
readily available at the location where the welding activities were l
being performed.
The WPS was qualified to the requirements of ASME l
Section IX and defines the quality characteristics on concavity limits (
of the weld root, removal of arc strikes, cleaning and preparation of l
weld joints, fit up and alignment requirements, welding gas quality, backing gas flow rates, off set limits, maximum and minimum tolerance on weld gap, interpass temperature and all of the essential variables
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of gas tungsten arc welding of stainless steel.
The inspector was informed that the procedure specification was a controlled document and maintained in the contractors office which would require the welders to travel down to grade level approximately 7 flights of staging, and out of the fuel handling building through a security check point to the contractor's office in order to read the WPS.
This arrangement does not make the procedure readily available to the welder and is considered to be a deviation from commitments to Regulatory Guide 1.143 and ANSI B31.1, 1977 edition (320/80-12-02).
The inspector noted during the inspection of pipe welding activities that there were no quality control procedures, inspection check lists, or any in process inspection activities inherent in a quality control program for the inspection of activities affecting quality.
The inspector was informed that the only inspection or verification required by the licensee would be a visual check and a hydrotest after completion per ANSI B31.1,1977 edition through the wintar 1978 edition and the inspection requirements of this class of pipe per Metropolitan Edison Procedure 3803, Revision 2.
This is considered to be a deviation from commitments to Regulatory Guide 1.143 (320/80-12-03).
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9.
Preoperational Test Inspection Review of Mini Decay Heat Removal (MDHR) System a.
Discussion The purpose of this inspection was to obtain preliminary information regarding the preoperational testing program for the mini decay heat removal system.
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Discussions, interviews and reviews included system description, i
system design criteria, diagrams, work schedules, turnovers, procedures, j
flushes, hydrostatic testing and preparations for preoperational l
testing.
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Also included were the scope of the test procedure review, test witnessing and test results evaluation.
b.
References l
References used for discussions, interviews and reviews by the inspector i
included the following:
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Letter from G. K. Hovey, Director TMI-2, to J. T. Collins, Deputy Program Director, TMI Program Office, dated April 7, 1980;
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Mini Decay Heat Removal System, April 7, 1980;
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Design Criteria TMI-2, Mini Decay Heat Removal System, February 26,
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1980 Revision 7; System Description, TMI-2 Mini Decay Heat Removal System, November
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14, 1979, Revision 0; Recovery Report, TMI-2 RR-Q2-80 Quarterly Progress Report for
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Period Ending June 30, 1980; Flow Diagram, Drawing B&R M043, Revision 7, Mini Decay Heat
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Removal System; and, Regulatory Guide 1.68, Initial Test Program for Water Cooled
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Nuclear Power Plants.
c.
Findings As a result of discussions and interviews with cognizant personnel, and examination and review of the referenced documents, the inspector had no further questions at this time.
Additional inspections will'be conducted when the preoperational test
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procedure is received for review by NRC: Region I.
10.
In Office, Review of Licensee Event Report (LER)
The inspector reviewed LERs submitted to the NRC: Region I office to veri *y that the details of the event were clearly reported, including the accuracy of the description of cause and adequacy of corrective action.
The inspector determined whether further information was required from the licensee, l
whether generic implications were indicated, anc whether the event warranted
- onsite followup.
The following LERs were revie'ed:
80-15/03L, Boric Acid Mix Tank Baron Concentration Out of Specification;
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t 80-16/03L, Out of Specification Fuel Oil Level (Low) for Balance of
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Plant (Gray) Diesel Generator; 80-18/03L, Voltage Output on Balance of Plant (White) Diesel Generator
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Upon Startup;
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- 80-10/01L, Loss of Steam Generator (B) Level Indication; and,
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- 80-20/Oll, Containment Integrity Not Maintained Due to Procedure
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Inadequacy.
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- TF:.; reports are selected for onsite followup and will be addressed in a later inspection report.
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The resident inspector also discussed the reports with the report writers for clarification on the basis for which specific codes were used on the LER form.
No items of noncompliance were identified.
11.
Unresolved Items Unresolved items are findings about which more information is needed to ascertain-whether it is an item of noncompliance, a deviation, or acceptable.
Unresolved items reviewed / disclosed during this inspection are discussed in paragraphs 2 and 5.b.
12.
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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