IR 05000320/1993007
| ML20059D700 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/23/1993 |
| From: | Conners E, Marilyn Evans, Kennedy J, Joseph Nick, Scholl L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20059D687 | List: |
| References | |
| 50-320-93-07, 50-320-93-7, NUDOCS 9401100042 | |
| Download: ML20059D700 (21) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
93-07 Docket No.
50-320 License No.
DPR-73 Licensee:
GPU Nuclear Corporation P.O. Box 480 Middletown, PA 17057 Facility:
Three Mile Island Station, Unit 2 Location:
Middletown, Pennsylvania
Inspection Period:
November 1,1993 - December 17,1993 Inspectors:
Michele G. Evans, Senior Resident Inspector Eben L. Conner, Project Engineer Joseph L. Nick, Radiation Specialist Larry L. Scholl, Reactor Engineer l
V ad b. kg*Rh
/A /dM43 Approved by:
Janet L. Kennedy, Acting Chief Date Reactor Projects Section No. 48 i
Insoection Summary:
This was an announced inspection to review and evaluate the licensee's completion of Post-Defueling Monitored Storage (PDMS) Requirements and Commitments for TMI-2.
Results:
No violations or deviations were identified. Of the thirty-three PDMS Requirements and Commitments assigned to the Region I staff for review, all were found to be satisfied to support the licensee's entrf nto PDMS.
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9401100042 931223 PDR ADOCK 05000320 G
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1.0 BACKGROUND AND PURPOSE General Public Utilities Nuclear Corporation, GPUN, is in the final phase of the current cleanup effort at Three Mile Island Unit 2 (TMI-2). Since the March 28,1979 accident, the
licensee has conducted a comprehensive cleanup program designed to place the facility in a I
safe and stable configuration. Following mitigation of the accident and stabilization of the
facility, the licensee's major efforts over the past 14 years have included partial facility _
decontamination, removal of fuel from the reactor vessel and other facilities, shipment offsite of substantial quantities of both high and low Icvel radioactive wastes, and the removal, treatment, and partial disposal of the accident generated water. The licensee has proposed placing the facility into long term storage until Three Mile Island Unit 1 (TMI-1)
permanently ceases operation in 2014, at which time both facilities would be decommissioned. The long term storage period for TMI-2 is called Post-Defueling Monitored Storage (PDMS). PDMS is a passive, monitored state similar to the SAFSTOR option of decommissioning.
In a letter dated January 15, 1993, the licensee submitted to the NRC staff a proposed list of PDMS Requirements and Commitments for TMI-2. This list was developed by the NRC i
staff and the licensee during a series of meetings at the TMI-2 site during the fall of 1992.
A letter dated May 19, 1993, documented the NRC staff's completion of the review of the proposed list and its acceptability. Since that time, NRC Headquarters and Region I staffs
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have been working to verify completion of the various items.
j The purpose of this inspection was to review and evaluate the completion status of the thirty-
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three PDMS Requirements and Commitments assigned to the Region I staff for review. In addition, the Region I staff provided input to the Headquarters staff for one item. The item i
numbers in this report correspond to the revised list of PDMS Requirements and Commitments for TMI-2 identified in a letter from GPUN to the NRC, dated November 12, 1993.
2.0 LICENSE CONDITIONS 2.1 (Item 2.F.b) Site Radialbn Protection Plan The Site Radiation Protection Plan submitted by GPUN contains the elements for protection against radiation and radioactivity for the TMI-2 facility. The plan outlines how the facility will be managed and maintained during P7MS to minimize risks to employees, contractors, visitors, and the public from radiation 01 adioactivity. The elements contained in the plan include the following: the basis for the radiological controls program; the program for maintaining radiation exposures as low as reasonably achievable (ALARA); the.
responsibilities of workers; audits, reviews, and reports on the radiological controls program; radiological controls training; control of external exposure; control of internal exposure; control of radioactive contamination; control of radioactive materials; and the radiological controls organizatio *
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When implemented, the Site Radiation Protection Plan will provide an adequate outline to protect the safety of the workers and visitors from radiation and radioactivity while in the i
licensee's facility. In addition, the licensee has developed detailed radiological controls l
procedures that are based on the elements contained in this document. The inspector found
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that the Plan, together with the procedures, offers a comprehensive program for radiation i
protection and radiological controls. The inspector concluded that this license condition has i
been met.
2.2 Otem 2.F.f) Plant Radiation and Contamination Surveys An NRC contractor (Pacific Northwest Laboratories or PNL) visited the site during the period from November 15,1993 to November 19, 1993. An NRC Region I Radiation Specialist also visited the site for most of the same time period. The Region I inspector verified that the contractor personnel performed representative radiation sampling of the licensee's radiologically controlled areas to provide independent measurement information.
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The contractor personnel surveyed approximately 20 rooms, areas, or cubicles for general
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area dose rates and contamination levels. The areas were determined by reviewing
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I documentation of radiation surveys previously performed by the licensee.
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Contamination samples were obtained from 25 to 30 locations per selected area. These sample locations closely approximated the locations sampled by the licensee. The samples
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were counted for determination ofloose beta and gamma contamination. Approximately 12 samples were counted for alpha contamination, but only minor alpha radiation was detected.
General area dose rates for beta and gamma radiation were determined by independent instrumentation and were compatible with licensee dose rates.
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The inspector concluded that the areas and sample locations selected by the contractor personnel were representative of the licensee's facility and sampling program. The l
contractor will submit a completed report of their radiation survey determinations in early 1994 to the NRC Office of Nuclear Reactor Regulation (NRR). The results of the Region I i
Radiation Specialist's review have been provided to NRR, which has the responsibility for
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verification of this license condition.
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3.0 ADDITIONAL REQUIREMENTS / LICENSEE COMMITMENTS 3.1 JIATION SAFETY AND REDUCTION OF POTENTIAL FOR RELEASES 3.1.1 Otem B.1) Ship off-site or package and stage for shipment remaining radioactive waste from the major TMI-2 decontamination activities.
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The NRC Region I Radiation Specialist reviewed the licensee's total waste volume generated from the major decontamination activities. Approximately 6 million gallons of contaminated reactor coolant or activated water was processed through the licensee's evaporator system.
l The water was evaporated and released to the atmosphere under monitored conditions. The contaminated sludge deposits (evaporator bottoms) were processed, packaged and shipped to a landfill for burial.
The licensee processed and shipped approximately 60,000 cubic feet of contaminated or l
activated material with 8400 Curies to a landfill for burial in preparation for PDMS during the period from April 1990 to October 1993. This number does not include nuclear fuel or special nuclear material shipments.
The inspector performed tours of the facility and found only a small amount of material staged or waiting for shipment. All radioactive waste from major decontamination efforts was processed or shipped for disposal. The inspector concluded that the licensee had met this commitment.
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3.2 PHYSICAL MAINTENANCE IN THE AUXILIARY AND FUEL HANDLING BUILDLNGS 3.2.1 (Item F.2) Ensure that both fuel pool structures remain intact.
The licensee, under Mini-Mod B-3160-90-0188 and Unit Work Instruction (UWI) 92-J186.00 for Spent Fuel Pool (SFP) 'A' and under Mini-Mod B-3160-93-0246 and UWI 93-J216.00 l
for SFP 'B', fabricated and installed a steel roof deck over both TMI-2 SFPs. The covers l
include HEPA filters and access ports. Because of significantly higher radiation levels from SFP 'A', that cover is completely sealed with caulk. The commitment to keep the SFP structures intact is documented in the TMI-2 PDMS Safe.ty Analysis Report (SAR), Section
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7.1.3, Amendment 17.
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The inspector reviewed the mini-mod and UWI packages and physically observed the two SFPs including the covers installed as authorized by the above mini-mods. The cover over SFP 'A' is located just below the pool ventilation system suction. The cover has four cutouts that provide the following functions. One cutout is for the Fuel Handling Bridge grapple tube that was left in-place and the cover sealed around the tube. A second cutout for venting the pool is covered with a HEPA filter. The two remaining cutouts, covered and sealed with a removal plate, are access ports over the Fuel Transfer Tube valves. The inspector observed that, contrary to Mini-Mod 90-0188 requirements, the caulk around the flashing had either fallen into the pool or was not correctly installed. The licensee stated that the caulking had been put on the flashing prior to screwing it to the wall. They agreed to re-caulk as necessary to insure all gaps were filled, per the mini-mod requirement. The inspector confirmed that this work was completed.
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The cover over SFP 'B' is at the top of the pool wall, above the pool ventilation system suction. The cover has three approximately 2 x 2 foot open ports with one covered by a i
HEPA filter. The two additional ports are, according to Mini-Mod 93-0246, to be enclosed / covered during PDMS. The inspector questioned how this would be tracked. The licensee responded that this mini-mod statement has been changed, since current plans are to leave the Fuel Building heating, ventilation and air conditioning (HVAC) operating. Item 16 of Operation's PDMS Dismantlement / Ongoing List is to install two covers on the 'B' SFP roofif the HVAC is secured. Based on the information reviewed, the inspector concluded l
that both SFP structures will remain intact.
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l 3.3 PHYSICAL MAINTENANCE IN OTHER BUILDINGS l
l 3.3.1 (Item G.1) Ensure that the Control Room Ventilation Systems (i.e., Cor.irol
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Room HVAC and Cable Room HVAC) and the Service Building Ventilation
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i System are maintained in an operational condition and will be operated as
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required.
The licensee stated that, generally, the PDMS operational ventilation systems will pmvide i
about half the original design flow. In particular, Amendment 18 to SAR Chapters 7.2.6.8, 9, and 10 states that the control room HVAC system will be maintained to provide fresh, filtered, heated or cooled air to support personnel occupancy. Likewise, the same amendment states that the Cable Room and Service Building HVAC systems provide the same type of air for both personnel and equipment. These HVAC systems are not required
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l to operate, just be operable. When the systems are not operating, passive, filtered pathways for equalization to atmospheric pressure are provided. The SAR refers to Figure 7.2-49 for detailed configuration. However, the inspector noted that this drawing had not been modified. The licensee stated that the updating of flow diagrams is being tracked as Item U214 on the Turnover of TMI-2 Systems Listing.
The inspector reviewed the SAR and discussed the HVAC concept with the licensee's staff.
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Presently, the Control and Service Building's HVAC are operated in accordance with procedures 4210-OPS-3826.01, " Control Building HVAC," and 4210-OPS-3836.01, " Service Building Heating and Ventilation," respectively. These ventilation systems are currently operating and will continue to be operational in PDMS. Since the systems are affected by the ongoing electrical modification work (described in section 3.4.1 of this report), they are l
not in their PDMS condition. The electrical modification will result in powering only one set of supply and exhaust fans in these areas. The inspector reviewed procedures OPS-3826.01 and OPS-3836.01, and the preliminary PDMS Operational System Plan for the Control Building Heating and Ventilation System, PDMS-OSP-3826-001. The inspector found operation of the Control Room and Service Building HVAC systems, as necessary for personnel occupancy, acceptable. This commitment is considered satisfied.
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3.3.2 Otem G.2) Maintain the capability to process potentially contaminated liquids.
SAR Section 7.2.3, Amendment 18, states that portions of the Radioactive Waste -
Miscellaneous Liquid System (WDL) remain operational during PDMS. This status provides assurance that significant quantities of liquid wastes will not accumulate in an uncontrolled manner in the Auxiliary Building and Containment. Liquid radwaste in these buildings may result from either rainwater inleakage or PDMS activities and the licensee expects this amount to be less than 5000 gallons per year. The licensee controls the processing of Unit 2 liquids in accordance with OP 4215-OPS-3232.17, " Miscellaneous Liquid Radwaste Disposal."
The inspector reviewed the SAR, the Technical Evaluation of TMI-2 PDMS (TER), Section 5.4.2, " Routine Liquid Releases," and OPS-3232.17. The licensee has maintained the i
capability to process contaminated liquids through the EPICOR II system. The licensee.used the EPICOR II system to process liquid radwaste following the TMI-2 accident. This system is now deactivated and has been tumed over to TMI-1 management. However, the licensee
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has maintained the TMI-2 tie-ins to the EPICOR II system so that accumulated liquids can be processed, as necessary. Liquid storage capabilities have been provided for accumulation
'mtil sufficient quantities are available for batch processing through the EPICOR Il system.
Although the existing TMI-l and TMI-2 WDL system tie-ins have been isolated, the licensee has retained the capability to process Unit 2 low-level liquid radwaste through the EPICOR II
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system in ar.ticipation of the eventual deletion of the TMI-l Condition of Operation prohibiting the transfer of TMI-2 liquid to TMI-1. The inspector concluded that the licensee
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has maintained the capability to process potentially contaminated liquids, therefore this commitment is satisfied.
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3.4 ELECTRICAL RELATED i
3.4.1 ELECTRICAL DISTRIBUTION SYSTEM CONFIGURATION FOR PDMS
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The NRC reviewed the electrical system requirements for PDMS and documented this review
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in section 6.6.1 of the TER. The conclusion of the NRC technical review was that,
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considering the post-accident, inoperable, and essentially defueled condition of the facility, electrical power is not required to maintain the safety of the facility. During PDMS, electrical power will not be required to mitigate the consequences of an accident, but is necessary for fire detection capability, monitoring of radioactivity and lighting for l
maintenance and surveillance activities. In section 7.2.5 of the SAR, GPUN committed to
maintain an adequate electrical power capability. The licensee is currently modifying the TMI-2 electrical distribution system to ensure that a reliable source of electrical power will be available to necessary loads during PDMS. GPUN expects the modification to be
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completed by March 1994.
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Originally two 230/4.16 kv auxiliary transformers powered the 4160 volt buses which then i
supplied power to a 4160/480 volt transformer associated with each of twenty-six 480 volt Unit Substations (USSs). These unit substations then provided power to twenty-six 480 volt motor control centers (MCCs). The 480 volt system provides power for motor, lighting and
heating loads as well as supplying power to transformers that feed the 120/208 volt system.
The modification provides power from a 13.2 kv offsite power source to five USSs through new 13.2 kv/480 volt transformers. These USSs then power one additional USS and three MCCs. GPUN decided to implement this design to achieve the following benefits:
e eliminate the connection to the 230 kv feed to minimize the possibility of an electrical problem on Unit 2 affecting the operation of Unit 1; e
eliminate the need to maintain the 4160 volt buses and remove the 4160/480 volt transformers that have experienced numerous failures; and e
consolidate the loads onto a minimum number of buses and reduce the possible sources of fire.
Two 120 volt distribution panels will be utilized to supply control and instrumentation power, including the fire detection, communication and annunciator systems. These panels receive power from a USS through step down and voltage regulating transformers. For added reliability, the panel that supplies the fire detection systems and annunciators has an alternate source from the Unit I station blackout diesel MCC through an automatic bus transfer switch.
Direct current (DC) loads are supplied from a single distribution panel that is powered from a rectifier / charger. The battery rectifier / charger receives 480 volt power from USS 2-22E and has a DC capacity of 100 amps. The rectifier / charger also has an alternate 480 volt supply from the Unit I station blackout bus through an automatic transfer switch. This panel supplies DC power to the fire protection panels and control power for the operation of the 480 volt circuit breakers.
3.4.2 (Item H.1) In Reactor Containment, Reactor Building electric power circuits will be deenergized except those necessary for PDMS monitoring, inspection, and surveillance equipment and other PDMS support requirements.
This commitment is discussed in Section 7.1.1.4 and Supplement 1, Number 17 of the SAR and is intended to minimize the potential fire ignition sources in the containment during.the PDMS period. The inspector discussed the status of electrical power circuits inside of the Reactor Building with GPUN engineers and reviewed the associated electrical one-line drawings and procedures.
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r Procedure 4210-OPS-3760.01, " Operation of TMI-2 Reactor Building Lighting," describes the power supply for reactor building lighting and miscellaneous power. There are four Portable Power Distribution Centers (PPDCs) located in the Reactor Building, two on each of the accessible levels. Two of the PPDCs are fed from USS 2-35 and two from USS 2-45.
The PPDCs provide 480/240/120 volt ac power to support containment activities and also
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power lighting fixtures that were added to eliminate the need to use the originally installed lighting system due to the poor physical condition of the fixtures and wiring. The added i
lighting system and several surveillance cameras are the only normally connected loads on the PPDCs. The power supply to the original lighting was eliminated by the electrical system modification.
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The inspector reviewed the electrical drawings associated with the electrical system modification and did not identify any additional power circuits that would be energized inside the Reactor Building. The inspector concluded that GPUN has climinated unnecessary power circuits m the Reactor Building and has satisfied this commitment.
3.4.3 (Item H.2) In the Auxiliary Building, the power to lighting, fire detectors, and sump level indication circuits will be energized and will remain operational. The auxiliary sump, auxiliary sump tank and associated level indication will also remain operational.
3.4.3.1 Lighting The inspector reviewed the lighting that is to remain operable during PDMS as described in
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PDMS-OSP-3760-001, " Operational System Plan (OSP) for Normal and Emergency Lighting Systems." During PDMS, one-half of the normal lighting will remain operable in all of the buildings except for the 328 foot elevation of the Auxiliary Building where fulllighting will l
be provided, and in the Reactor Building that has added lighting as described in section 3.4.2 (Item H.1), above. Prior to eliminating any lighting, a plant walkdown was performed by
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l members of the safety, operations and engineering departments with only the planned PDMS lighting energized to ensure that it would be adequate. This team concluded that the proposed PDMS lighting would be sufficient.
Tables 1,2, and 3 of the OSP provide a listing of the panels required to be energized to power the lighting. The inspector reviewed the electrical system modification drawings and confirmed that the panels listed in the OSP would be powered following the modification to the TMI-2 electrical distribution system. The inspector also noted that GPUN plans to keep all of the 120 volt receptacles energized and since these circuits power the battery chargers for the battery operated emergency lighting, these emergency lights will also remain operable.
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3.4.3.2 Fire Detectors i
The inspector reviewed TMI-2 operating procedure 4210-OPS-3810.01, " Fire Protection System," Table 7.2, to determine what circuits were required to energize the fire protection system. The electrical modification drawings were then reviewed to check that necessary panels would remain powered or that the circuits had been reassigned to the 120 volt ac or 125 volt de system described above. The inspector found that all the required circuits were powered and most of the circuits are connected to the panels that have a backup source of power through the automatic bus transfer switch. Three circuits identified are powered from miscellaneous power panels that would be deenergized if the TMI-2 main power supply is lost. Section 7.2.1.5.3 of the SAR states that backup power has been provided to support the fire protection system during a temporary loss of power. The inspector discussed the implications of the three circuits not having backup power with the licensee. The licensee stated that in the event power to these circuits was lost, the need to take compensatory
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measures, such as establishing a fire watch, would be evaluated and implemented in accordance with the fire protection plan. GPUN plans to revise Section 7.2.1.5.3 of the SAR to clarify the capabilities of the backup power.
3.4.3.3 Sump / Sump Tank Level Indications The inspector verified that the auxiliary sump pumps and auxilia y sump tank pumps will be powered during PDMS. All pump operations are manual and the only instrumentation required are the high level alarms that receive power from the control transformer in the
MCC.
3.4.3.4 Conclusion The inspector concluded that GPUN has adequately provided power to energize lighting, fire detectors and sump level indications in the Auxiliary Building.
3.4.4 (Item H.3) In the Fuel llandling Building, low voltage circuits to lighting and fire detection will be energized.
This item was reviewed and found to be satisfactory. Refer to the discussion of Item H.2, in Section 3.4.3 above.
3.4.5 (Item II.4) in the Control and Service Buildings, verify that the electrical distribution will remain configured to power low voltage lighting loads and fire detectors.
This item was reviewed and found to be satisfactory. Refer to the discussion of Item H.2, in
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Section 3.4.3 above.
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3.4.6 (Item H.5) Portions of the TMI-2 electrical distribution system will be operational and energized to provide power for the PDMS support systems and their associated controls and instrumentation. Power will be available for area lighting, receptacles, heating, and ventilation to support PDMS activities.
The inspector reviewed section 7.2.5 of the SAR and the electrical modification being implemented as described above. From a Irview of modification T2-MM-225012-001 -
documentation and drawings, and through discussions with the licensee, the inspector concluded that the modification will result in the electrical distribution system described in the SAR. The inspector performed a plant walkdown and noted that three of the USSs were energized from the 13.2 kv feeder and work on the fourth was in progress. The necessary equipment continues to be powered from the existing electrical system, or by the use of temporary feeds, during the transition to the modified system. The inspector concluded that this commitment was satisfied.
3.4.7 (Item H.6) Emergency lighting (8-hr portable emergency lights) is staged with emergency response crew equipment.
The inspectors inventoried the emergency response equipment and confirmed that portable emergency lights were in place. Procedure 1104-45R, " Fire Protection System Operations Surveillance," was reviewed and found to include a requirement to perform periodic inventories of the Unit 2 fire equipment locker and ensure the lights are operable. The inspectors concluded that this commitment is satisfied.
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3.4.8 (Item II.7) Verify that exit signs are powered from the normal lighting system.
The inspector found that the exit signs are powered from the 120 volt lighting and receptacle
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panels and are included in the modification to be powered during PDMS. This commitment is satisfied.
3.4.9 (Item II.8) DC power during PDMS will be available. Loads have been consolidat where practicable to reduce the number of energized circuits.
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power a 125 VDC PDMS distribution panel. This panel powers five DC distribution panels '
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onto which all of the DC loads have been consolidated. The inspector reviewed drawing i
201-267, "DC Distribution PaneIs," to confirm that only necessary loads remain energized.
The inspector concluded that this commitment is satisfied.
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3.5 FIRE PROTECTION 3.5.1 (Item I.3) Ensure that either the TMI-2 control room or some other location is continuously manned with a fully qualilled person or that remote monitoring
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i capabilities are available in TMI-I control room to identify the specific zone panel which indicates the location of the fire in the TMI-2 facility. Ensure that f
procedural control exists to delineate the location of the monitoring activity.
In accordance with Section 7.2.2.2.b of the SAR, the licensee implemented a system modification to allow monitoring of critical alarm functions (fire, sump level, radiation release, etc.) and station vent monitor signals within TMI-2 via the TMI-l Computer System and alarm CRTs in the TMI-1 Control Room. The modification as described in Modification Design Description, MDD-TI-660A, included installation of two fiber optic cables between the TMI-l Computer System cabinets in the Operations Support Facility and a new multiplexer cabinet installed in the TMI-2 Control Room. The licensee also installed a Mini-Uninterruptible Power Supply (UPS) to provide 120 VAC input power for sufficient time to allow for operator response in case of primary AC source power failure. The licensee also performed modifications to allow for TMI-2 PDMS alarm monitoring within the TMI-2 Control Room in case the multiplexer or link to the TMI-l computer system is out of service.
The inspector reviewed MDD-T1-660A, TMI-l Operating Procedure (OP) 1105-22, " Unit 1 Response to Unit 2 PDMS Alarms," and procedure 1000-PLN-1300.01, "GPU Nuclear Corporation Emergency Plan for Three Mile Island and Oyster Creek Nuclear Station."
Procedure 1300.01, Section 5.1.3A states that TMI-2 Control Room alarms will be monitored on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day basis either directly by manning the TMI-2 Control Room or remotely in TMI-1. OP 1105-22, Section 2.2.1 states that if the TMI-1/TMI-2 Alarm Monitoring System becomes inoperable, within I hour the Unit 2 Control Room is to be manned for alarm monitoring purposes until the Alarm Monitoring System can be retumed to service. The inspector observed the remote PDMS Alarm Monitoring System, in the TMI-2
control room, and the alarming display CRTs in the TMI-l control room. TMI-l alarms indicate green, yellow and red for Priority 3,2 and I conditions, respectively. All TMI-2 alarms display as blue, Priority 4 conditions, on the CRTs. This system was fully operational at the time of the inspection; however, some data points may be changed (added or removed) prior to PDMS. The inspector concluded that this commitment was satisfied.
3.5.2 (Item I.4) Demonstrate that TMI-I Operations has accepted responsibility for maintaining the fire service system in operable areas of the plant as required to support operations in the waste-handling and packaging facility, the respirator cleaning facihty and the administration building.
In 1989, the licensee transferred ownership of portions of the fire service water system from TMI-2 to TMI-1 (Turnover Notice (TN) 3504-89-053). At that time the responsibility for maintaining the fire service system to support operations in the respirator cleaning facility
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l1 and the administrative building were transferred to TMI-l Operations. Responsibility for fire service to support operations in the waste-handling and packaging facility were transferred to TMI-l Operations in September 1993 (TN 3810-93-027).
The inspector reviewed the TNs and the pmcedures associated with the fire service systems in the waste-handling and packaging facility, the respiratory cleaning facility and the administrative building. The inspector verified that the licensee had the appropriate procedures in place for periodic testing of alarm functions, inspection of fire system sprinkler systems, conduct of fire system valve cycling, and verification of valve line ups for the three locations. Based on this review, the inspector concluded that this commitment was satisfied.
3.5.3 (Item I.5) Deactivate deluge systems in the Auxiliary Building and the Control Building.
SAR Section 7.2.2.3, Amendment 18, states that the deluge systems in the Auxiliary and Control Buildings have been deactivated for PDMS and that there are no deluge systems in the Containment. In a closeout memorandum of July 26,1993, GPUN documented that TMI-2 Operating Procedure (OP) 4210-OPS-3810-01, " Fire Protection System," maintains the isolation valves, FS-V-418B,419B,4208,421B,422B,423B,4248,433B, and 507, closed. This deactivates the Auxiliary and Control Building deluge systems.
The inspector verified that the nine isolation valves are specified " Closed" in OP 4210-OPS-3810.01 and physically confirmed that the valves were closed and tagged out-of-service. In addition, the inspector verified that the same specification is contained in TMI-1 OP 1104-45Q, "TMI-2 Fire Protection System," issued November 10,1993. (The licensee stated that the Unit 2 procedure would be eliminated in about one month.) The inspector noted that the nine valves were shown on Drawing 2037, Revision 25, as "Open". The licensee stated that the policy had been to make drawing changes for physical changes, but not to indicate normal valve position conditions. The licensee prepared Document Change Notice (DCN)
2037-SH-1-25-01 to make these drawing changes. The inspector also confirmed that, although the deluge systems are deactivated (no water to nozzles), the related fire detector alarms were left operable as required. The inspector concluded that the deluge systems in the Auxiliary Building and the Control Building had been deactivated and, therefore, this commitment is satisfied.
3.5.4 (Item I.6) Ensure that all IIalon systems have been deactivated by disconnecting the cylinden and either emptying or removing them.
SAR Section 7.2.2.2.d specifies that the Halon systems protecting the Air Intake Tunnel i
(AIT) and the Cable Relay Room (CRR) have been deactivated by either removing or emptying the halon cylinders and deenergizing the ultraviolet and pressure detectors. Agam, the fire detection system will remain operational to monitor these areas. The licensee stated I
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that these were the only two Halon systems at TMI-2. The requirement for the two Halon systems have been removed from TMI-2 OP 4210-OPS-3810.01. In addition, the same requirements have been removed from the TMI-l OP 1104-45Q.
The inspector reviewed the above documentation and discussed the removal of the Halon i
systems with the licensee. The Halon system for the AIT was deactivated by two Job Ticket (work request) forms. CI948 (102589), " Remove Explosive Actuators from Air Intake Tunnel Halon System and Dispose of per Security Direction," was completed in October, 1989. CJ272 (091393), " Removal of Air Intake Tunnel Halon Bottles, etc.," was completed in Octobe,1993. The CRR was originally protected by two banks of Halon cylinders. The licensee documented the condition of the Halon system for the CRR in a closeout memorandum of October 7,1993. In March 1987, one bank of Halon cylinders was manually discharged and never recharged. These empty cylinders were recently removed from the Unit 1/ Unit 2 cross-corridor. The second bank was removed at a later time, but no paperwork is available. The inspector physically viewed the location of both Halon banks and found that they had been removed. Drawing 2037, Sheet 2, shows the CRR Halon system, with cylinders and other equipment, with no indication of system deactivation. The licensee prepared DCN 2037-SH-2-22-01 to correctly indicate the as-built configuration. The
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I inspector concluded that the Halon systems have been removed from TM1-2 and, therefore, this commitment is satisfied.
3.5.5 (Item I.7) Verify that portable fire extinguishers am staged with emergency response crew equipment.
SAR Section 7.2.2.2.e, Amendment 18, states that portable fire extinguishers are staged with the emergency response crew equipment (more commonly called the Fire Brigade Equipment Storage Building). TMI-l OP-1104-45L, " Portable Fire Fighting Equipment," specifies that manual fire fighting equipment consists of dry chemical, carbon dioxide, halon, and pressurized water fire extinguishers. TMI-1 Preventive Maintenance (PM) procedure U-10 provides the guidance to inspect the various types of portable extinguishers, hoses and nozzles.
The inspector reviewed the above documentation and toured the TMI-2 fire protection areas.
The Fire Brigade Equipment Storage Building is well supplied and organized with the required equipment. GPUN also maintains a step-van with additional equipment for faster assess to remote fire areas. The step-van's normal location is near the Security Processing Center. Ponable fire extinguishers were located in numerous areas around the Unit 2 complex. The inspector confirmed that a sample number of the portable units were properly inspected and tagged. The inspector concluded that portable fire extinguishers are adequately staged and maintained, and, therefore, this commitment is satisfie.5.6 (Item I.8) Verify that self-contained breathing apparatus are staged with emergency response crew equipment.
SAR Section 7.2.2.2.e, Amendment 18, states that self-contained breathing apparatus are staged with the emergency response crew equipment. The inventory of the fire fighting equipment is performed per TMI-1 Administrative Procedure (AP) 1038, " Administrative Controls - Fire Protection Program," using surveillance procedures OPS-S152, " Fire Fighting Emergency Equipment Inventory," OPS-S297, " Inspection of Fire Brigade Vehicle Equipment," and OPS-S390, "TMI-2 Fire Fighting Equipment Inventory."
The inspector reviewed the most recently performed surveillances OPS-S152, S297 and S390. These surveillances are performed monthly, weekly and quarterly, respectively, as specified by AP-1038. The licensee stated that OPS-S152 was the main surveillance procedure for the Fire Brigade Equipment Storage Building, that OPS-S297 was performed to ensure that the automotive portion of the step-van was operational, and that OPS-S390 surveyed an extra locker (in the Unit 1/ Unit 2 hallway) maintained strictly for convenience.
The inspector toured these three areas and found that the appropriate self-contained breathing apparatus was staged. However, of the three surveillances, only OPS-S297 for the step-van, listed the requirement for Scott Air Packs. In response to the inspector's questions regarding inventory control and surveillance of self-contained breathing apparatus, the licensee said that this was controlled by TMI Emergency Preparedness Procedure Manual 6410-ADM-1300.05,
" Emergency Equipment Readiness." Attachment 18 to this procedure is a data form for self-contained breathing apparatus. The inspector reviewed this surveillance performed in October of 1993, which indicated that the required breathing apparatus was checked. The licensee initiated action to include the breathing apparatus inventory check in OPS-S152 and OPS-S390. General instructions for maintaining breathing equipment were contained in a recently revised TMI-2 Administrative Procedure (AP),4232-ADM-4020.01, " Inspection and Maintenance of Respiratory Protection Equipment." No comparable TMI-l AP was identified. The licensee took action to ensure this procedure is converted to a TMI station procedure. With these corrective actions initiated, the inspector concluded that sufficient self-contained breathing apparatus are properly staged and maintained for emergency use.
3.5.7 (Item I.9) Ensure that the fire detection system remains operational in the Air
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Intake Tunnel and the Control Relay Room.
SAR Section 7.2.2.2.d states that the fire detection system will remain operational to monitor the Air Intake Tunnel (AIT) and the Control Relay Room (CRR). Item b of the same section indicates that Table 7.2-4 list those areas where fire detection is operational (PDMS status
"OS") or deactivated (PDMS status "DS"). Table 7.2-4 indicates that for Fire Zones 9 and 9A (the CRR), and the 305 foot level of the Control Building, the PDMS status is correctly
"OS". The AIT detectors are not addressed in the SAR, however, TMI-2 OPS 3810.01 and TMI-l OP-1104-45Q specify that these detectors are required. In addition, these same procedures require the CRR fire detection system points to be operable.
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The inspector reviewed the above documentation and discussed the systems with the licensee staff. Both of the above mentioned procedures state that an auxiliary function of these t
j detectors is to " Actuates Halon Fire Suppression System." The licensee said that this is for
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alarm identification only, that the plant staff is aware that the halon is removed, and a recent
internal audit had identified the need to re-label plant components to remove the word
"Halon". The inspector reviewed the licensee's confirmation that these specific detectors
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will alarm directly in the TMI-2 control room and remotely via the PDMS alarm monitoring system in the TMI-1 control room. This review is documented in section 3.5.13 of this i
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report (Item I.22). Based on this review, the inspector concluded that the Unit 2 fire j
detection system in these two areas will remain operational.
j 3.5.8 (Hem I.11) To the extent that fire protection is not requimd in work or storage l
areas, ensure isolation of the 12-inch fire service loop, which runs through the
Auxiliary and Fuel Handling Buildings, the Control Building area and the Turbine Building (east and west).
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At the present time, Auxiliary and Fuel Handling Building systems, such as the deluge j
systems discussed in section 3.5.3 above (Item I.5), have been isolated by closing the required valves. The Turbine Building will be isolated and drained, per TMI-l OP-1104-
J 45Q Section 5.3, when the electrical modification work described in section 3.4.1 above is
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completed.
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The inspector reviewed the above documentation, discussed the system conditions with the j
licensee, and physically observed the systems involved. Based on these actions, the inspector
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concluded that to the extent that fire protection is not required in work or storage areas, the j
i fire service loop has been isolated.
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3.5.9 (Item I.12) Ensure that the fire system line is cut and blanked off at the Fuel-
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Handling Building, where the fire system line runs from the Diesel Generator i
Building.
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SAR Section 7.2.2.2.i states that isolation of the 12 inch line has been done. This
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modification, cutting and blanking off of the 12 inch fire system supply line at FS-V-137, j
was performed under Unit 1 Modification BA-412567, " Station Blackout Diesel." In a GPUN Memorandum, dated January 19, 1993, the completion of the subject modification j,
was documented.
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The inspector reviewed the above documentation, discussed the modification with the j
licensee, located and reviewed the changed drawings, and physically observed the blanked
off pipe. The capped 12 inch fire water to the Diesel Generator Buinaing is shown on TMI-l
Drawing E-302-231, " Fire Service Water," Revision 66 and TMI-2 Drawing 2037, " Flow
Diagram - Fire Protection," Revir'. 25. The inspector concluded that the fire system line is l
appropriately isolated and, therefore, this commitment is satisfied.
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3.5.10 (Items I.13 and I.14) Deactivate River Water Pump House and the Fire Pump House.
SAR Section 6.1.10, Amendment 18, indicates that during PDMS the River Water Pump House, the adjacent Fire Pump House, and the systems within these facilities serve no active
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or passive functions and as such are designated deactivated. TER Page 6-33 states that although the houses are deactivated for PDMS, a passive pathway for intake water to diesel fire pump, FS-P-1, will provide an emergency backup water-supply source. However, the licensee's intentions have changed since the TER was written (February 1992) and FS-P-1 is
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no longer needed as an emergency backup water-supply source. Under Mini-Mod A-3814-93-0267 and the related UWI J-285, the River Water and Fire Pump Houses were isolated by
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removing 2FS-V-148 and installing one blind flange and one pipe cover on the ends of the
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open piping. The deactivation of the River Water and Fire Pump Houses was performed
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under UW188-260 and the related Special Operating Procedure (SOP)88-260. The
deactivation of these pumps was documented in a memorandum dated October 28,1993.
Both the subject UWIs were closed out in early November 1993.
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The inspector reviewed the above documentation, discussed these modifications with the.
licensee, and physically observed the isolation points. This review included the procedures and drawings affected by these modifications. The inspector concluded that the River Water and Fire Pump Houses have been properly taken out of service and, therefore, these commitments are satisfied.
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3.5.11 (Item I.19) Train and familiarize station brigade with the TMI-2 system configurations, plant layout and procedures for TMI-2.
SAR Section 7.2.2.2.k states that the station fire brigade has been fully trained to assure that the personnel are familiar with system configurations, plant layout, and the procedures in Unit 2.
The inspector reviewed TMI-2 Unit Administrative Procedure Manual Number 4000-ADM-3680.01, " Fire Protection Program, Organization, Responsibilities and Authorities," TMI-l Administrative Procedure (AP) Number 1038, " Administrative Controls-Fire Protection Program," and Training and Education Department Training Programs Manual Number 6212-PGD-2680, "TMI Fire Protection Training Program." Procedure 4000-ADM-3680.01,
Section 4.7.2 states that TMI-l is responsible for providing qdified Fire Brigade Personnel in accordance with AP 1038 in order to meet the Fire Brigade requirements in TMI-2.
Sections 4.8 through 4.10 describe the TMI station fire brigade, fire brigade qualification and training requirements, and fire drill requirements. Procedure 6212-PGD-2680 establishes the implementation of the Fire Protection Training Program prescribed by the Fire Protection Programs for Units 1 and 2.
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The training program requires that the same personnel may serve as fire brigade members for both TMI-1 and TMI-2 only if members have received the appropriate unit specific fire service systems and preplans training. The inspector reviewed Initial Training Lesson Plan Number 11.4.01.N2, "Section 4: Pre-fire Plans, Detection and Suppression Systems," and Retraining Module 1, " Fire Protection Procedures, Fire Fighting Plan, and Offsite Interface," Module 5, " Pre-Fire Plans," and Module 8, " Fire Brigade leader," and verified that the material included the required fire service systems and preplans training for TMI-2.
The training program also requires that each fire brigade team leader act in the leader capacity for at least one TMI-2 drill per year. The inspector reviewed training records for four fire brigade team leaders, and four fire brigade team members who were assigned fire brigade duties on either November 14 or 18,1993. The inspector found that the individuals had received the appropriate TMI-2 specific training.
The inspector found that the licensee had established and was implementing an adequate program to train and familiarize the station fire brigade with TMI-2 system configurations, plant layout and procedures. Based on this review, the inspector concluded that this commitment was satisfied.
3.5.12 (Item I.21) Verify that the procedure for inspection of the fire loop drain valves during freezing weather is in place.
SAR Section 7.2.2.2.i, Amendment 18 states that 1-inch drain valves have been installed, are normally open for drainage purposes, and will be inspected monthly during freezing weather.
The licensee provided copies of TMI-1 OPS-S85, " OPS Winterization Checks," which requ res annual verification, on the fourth Monday in September, that the east and west fire i
system header isolation valves, 2/FS-U-151 and 150, are closed, and related drain valves, 2/FS-V-1300 through 1303, are open. This condition is required unless the Turbine Building fire water system has been returned to service per OP-11N-45Q. The same requirements are specified in TMI-1 procedure OPS-S449, "TMI-2 Fire System Header Freeze Protection,"
l where the checks are to be made monthly on the second Wednesday if the fire water system l
is not in use for building occupancy.
The inspector reviewed the above documentation, talked to the fire system engineer, and physically observed the subject isolation and drain valves. Since the fire water system was in use during the inspection for electrical modification work, the fire loop isolation and drain
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l valves were not in their freeze protection positions. The inspector concluded that procedures for inspection of the fire loop isolation and drain valves for freeze protection were in place and, therefore, this commitment was satisfied.
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i 3.5.13 (Item 1.22) Verify that the procedures and system are in place for testing of the operable portion of the fim detection and alarm system. (SAR 7.2.2.2b.; TER 6-34)
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SAR Section 7.2.2.2.b states that the fire protection system originally provided at TMI-2 will remain operational to provide covemge in the Auxiliary, Control, Fuel Handling and Reactor Buildings and the Fire Pump House. In TER Section 6.4.3, the reviewers found the licensee's commitment to test the operable portion of the fire detection and alarm system every 6 months by performing channel functional test and tests of supervised circuits
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acceptable.
The inspector reviewed the above documents, discussed this issue with the fire protection and startup and test engineers and physically viewed the PDMS alarm system. The licensee has confirmed the operability of the fire detection system through Unit 2 surveillance procedures 4210-SUR-3680.01,02 and 03 and preventive maintenance procedure 4210-PMG-3680.01.
The inspector reviewed these procedures and noted that: procedure SUR-3680.01, " Fire Detection Circuits Operability Check," provides monthly checks of the reactor building detectors; procedure SUR-3680.02, " Fire System Detector Instrument Functional Test,"
provides the six-month functional test of Technical Specification (TS) required detectors; procedure SUR-3680.03, " Fire Detection Circuit Operational Check," provides six-month
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operational checks of recovery plan areas; and procedure PMG-3680.01, " Fire detection Circuit Operational Check," provides the six-month operational check of balance of plant detectors. These procedures are in effect until PDMS is initiated.
The licensee has drafted three new TMI-1 procedures, replacements for the four listed above after entry into PDMS, to test the operability of the fire detection system from detector to computer alarm in the TMI-1 control room. Procedures IC-168, " Unit 2 Reactor Building Fire Detection Functional Test," and IC-169, " Unit 2 BOP Fire Detection Functional Test,"
l will provide detailed instructions on performing fire detector tests in specified areas. IC-168 l
and 169 are scheduled to be performed once per 6-months. Both of these procedures will
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confirm fire detection from the detectors to the TMI-2 control room, then to the TMI-1 PDMS computer alarm monitor. The other new operations surveillance procedure, OPS-S423, " Fire Detection Non-Supervised Circuits Check - Relief Crew," provides monthly checks for the operability of the fire detection alarms from the TMI-2 control room to the
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TMI-l PDMS computer alarm monitor. The inspector concluded that procedures and system are in place for testing the operable portion of the fire detection and alarm system now and after PDMS is initiated. Therefore, this commitment is satisfied.
3.5.14 (Item I.23) Verify that procedures for manual suppression of fire by the fire brigade are provided as stated in the FPPE.
Emergency Procedure (EP) 1202-31, " Fire," is the site controlling pmcedure for all fires.
Step 2.2.1 indicates that first warning of a TMI-2 fire would probably be from the PDMS
alarm system in the TMI-1 control room in accordance with OP-1105-22, " Unit 1 Response
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to Unit 2 PDMS Alarms." Step 3.7.c states that the Pre-Plan Strategies and Smoke Removal Plan should be used. The licensee stated that these strategies / plans are located in both
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l control rooms, the fire equipment storage building, the fire step-van, and the fire equipment l
cabinet in the Unit 1/ Unit 2 hallway. In addition, the strategies / plans are provided to the fire brigade leaders and the fire protection engineers.
The inspector reviewed the above documentation, discussed the program with the fire protection engineers, and had an extensive tour of the equipment locations. The inspector l
found that the fire strategies / plans are very complete for each plant area, providing system information, important hazard data, and detailed smoke removal plans. The inspector found this commitment to be satisfied.
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3.6 FLOOD PROTECTION l
3.6.1 (Item J.1) Ensure that flood panels are provided for all entrances to the Control Building, and to the entrance of the Auxiliary Building. Doors and entrances to l
l the Control Building area that are not flood-protected are either watertight or
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are provided with flood panels. All openings that are potential leak paths (i.e.,
ducts, pipes, conduits, cable trays) are scaled.
The licensee addresses site flood protection in SAR Section 7.1.4.2, Amendment 17. Flood panels are provided for all entrances to the Control and Auxiliary Buildings. Flood protection requirements have been established in Administrative Controls Section 6.7.1 of the present and proposed PDMS Technical Specifications. The licensee's Unit 2 procedure that meets the present TS requirement is TMI-2 Emergency and Abnormal Procedure 4210-EAP-1300.01, " Flood," dated December 21, 1991. The Unit 2 requirements have, more recently,
been placed in Unit 1 Emergency Procedure (EP) 1202-32, " Flood," dated August 19, 1993.
This procedure meets the proposed TS for PDMS conditions.
The inspector reviewed the SAR, the proposed TS, the subject procedures, and the TER.
The TER concluded that, "The staff finds that the flood protection requirements are adequate to minimize the probability of an inadvertent release of radioactive material from the i
facility." The inspector verified that EP 1202-32 addresses flood panel locations and sealing of manway covers for TMI-2. In addition, the inspector toured the facility and verified that i
flood panels were appropriately staged at the entrances to the Control and Auxiliary Buildings. The inspector concluded that this commitment was satisfied.
3.6.2 (Item J.2) Verify that the containment basement and Auxiliary Building sumps level indications will be maintained.
SAR Section 7.2.3.1, Amendment 19, states that in PDMS, portions of the Waste Disposal -
Liquid (WDL) system remain operational providing assurance that significant quantities of liquid wastes will not accumulate in an uncontrolled manner in the Auxiliary Building and Reactor Building (containment) basement sumps. Level indications will be maintained for
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i these two sumps. The detection of the Auxiliary Building sump level is direct and is monitored in accordance with OPS-3232.17, " Miscellaneous Liquid Radwaste Disposal."
Because of the extremely high radiation level in the Reactor Building basement, the licensee installed a manual bubbler assembly using a remote level gage to monitor the sump under Mini-Mod 3572-88-0146. This assembly taps into the decay heat removal pump suction
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piping immediately downstream of DH-V-6A, and is positioned to allow reading of the sump
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level through the access opening of the decay heat remote cooler valve in the Auxiliary
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Building basement. OPS-3572.01, " Reactor Building Sump Level Measurement / Drain,"
provides guidance on calculating the sump level from the gage reading.
The inspector reviewed the mini-mod and the subject procedures and discussed the sump level control with the licensee staff. Since the Reactor Building sump level is determined as stated above, no remote monitoring is possible. As a precursor to the transfer of TMI-2
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monitoring to the TMI-l staff, verification of detection-to-computer-alarm was performed by the licensee's Startup and Test personnel. The inspector discussed the post modification I
testing of the Auxiliary Building sump level alarms with licensee personnel and found it to be acceptable. However, the inspector questioned the testing frequency for these alarms. The licensee responded that since no systems can feed these sumps (except for Auxiliary Building environmental leakage), and routine building surveys will be performed, periodic testing is
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not required. The inspector concluded that this commitment was satisfied.
l 3.6.3 (Item J.3) Verify that the Auxiliary Building sump pumps are maintained i
operational and placed in a manual control mode.
l The licensee indicated that this commitment is met by SAR Section 7.2.3.1.2, last modified by Amendment 10 in January 1992. However, the inspector noted that Item 7.2.3.1.2.c
states; "The Auxiliary Building sump has dual pumps that operate automatically and
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alternately to equalize run times." Apparently, this statement had been inadvertently left in the SAR, because the licensee had indicated to the inspector that power would be supplied to only one pump at a time, after the electrical modification is completed (discussed in section
3.4.1). The licensee corrected this statement in SAR Revision 19, issued November 12, 1993. Operation of the pumps is controlled by procedure OPS-3232.17, " Miscellaneous
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Liquid Radwaste Disposal."
The inspector reviewed OPS-3232.17 and verified that the procedure specified that the pump control will be kept in manual and started only after evaluating the situation. The inspector concluded that the Auxiliary Building sump pumps are being maintained operational in the manual control mode and, therefore, this commitment is satisfied.
3.6.4 (Item J.4) Verify that the Miscellaneous Waste Holdup Tank (MWHT) and the
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Auxiliary Building Sump Tank (ABST) have been isolated from the Radwaste Disposal Gas System and vented via HEPA filters to protect against airborne releases from these tanks.
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The licensee states in SAR Section 7.2.3.1.2 that, since the Radwaste Disposal Gas System (RDGS) has been deactivated, the MWHT and ABST have been isolated from the RDGS and vented through cartridge type HEPA filters to protect against airborne releases from these tanks.
The inspector reviewed UWI 92-J199, " Venting of Plant Tanks and Waste Gas Decay Tanks for PDMS," which included Mini-Mod A-3231-92-0231. The physical work was completed in April 1993, and Operating Procedure (OP) 4210-OPS-3231.01, " Waste Gas Disposal System," and Drawings 2028, "Radwaste Disposal - Gas," and 2045, "Radwaste Disposal Miscellaneous Liquids," were updated per DCNs in June 1993. The inspector reviewed OPS-3231.01 and updated drawings 2028 and 2045. This procedure has been prepared for use at the time of PDMS implementation, so a completed checklist was not available.
However, partially completed checklists were seen at the procedure control point. Drawing changes, showing the location of the HEPA filters, were reviewed and found acceptable.
The inspector concluded that this commitment was satisfied.
3.6.5 (Item J.8) Ensure that the active sumps have a high level alarm that annunciates in the control room and the PDMS Alarm 11onitoring System.
The licensee states that a number of building sumps are left operational to assure that water buildup does not cause adverse localized flooding. They expect these sumps will contain water that is either clean or slightly radioactive. Amendment 18 changed SAR Section 7.2.3.2 to correct the as-built modification design description for the PDMS sump alarm monitoring system. Tiie 10 sumps to be left operational, with level alarms active on the PDMS alarm system in the TMI-l control room, are listed in SAR Table 7.2-3.
The inspector reviewed controlling procedure, TMI-1 OP-1105-22, " Unit 1 Response to Unit 2 PDMS Alarms," for the 10 sump alarms. It was noted that, although the revision was June 1993, many of the alarm causes listed " Failure of the sump pump to start" as the first item.
Since the SAR states that the sumps will normally be operated in a manual control mode, with a high level alarm that annunciates in the control room and the PDMS Alarm Monitoring System, these statements appeared to be in conflict. The licensee initiated a Procedure Change Request (PCR) to replace the above words with statements indicating that the water level is increasing in the sump. The inspector confirmed that 9 of the 10 sumps of interest were covered by this draft PCR. The tenth sump, the containment building sump, has no remote sump level instrumentation as discussed in section 3.6.2 (Item J.2), above.
The inspector concluded that this commitment was satisfied.
4.0 NRC MANAGEMENT MEETINGS The inspectors met with licensee personnel at the conclusion of the inspection period on December 17, 1993. At that time, the scope of the inspection and inspection results were summarized.
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