ML19210B604

From kanterella
Jump to navigation Jump to search
Insp Rept 50-289/74-29 on 740813-16.Noncompliance Noted: Failure to Properly Control & Recalibrate at Specified Frequency Brush Recorder Used During Generator Trip Test & Other Earlier Initial Startup Tests
ML19210B604
Person / Time
Site: Crane Constellation icon.png
Issue date: 09/06/1974
From: Davis A, Spessard R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19210B602 List:
References
50-289-74-29, NUDOCS 7911110043
Download: ML19210B604 (18)


See also: IR 05000289/1974029

Text

-

,

. .

.. ....

- -.

. . . . . . . . . . .

.

. . . . . - . .

- . . .

. . - .

. . . . - . - -

-

.

..s

~

,

.

.,

, . . . .

.

,

( %_

t.

.

..

.

.

.

-

.

U.S. ATOMIC E::ERGY C0:0!ISSIO:1

.

DIRECTORATE OF RECULATORY OPERATIONS

-

REGION I

'

RO Inspection Report No:

50-289/74-29

Docket No:

50-289

l

f

.

DPR-50

l

Licensee:

Metropolitan Edison Company

License No:

.

'

Three Mile Island Unit 1

Priority:

B-2

Category:

.

Location:

Middletown, Pennsylvania

.

.

.

Typ'e of Licensee:

PWR 871 MWe (B&W)

Tpe of Inspection:

Routine, Announced

G{DatesofInspection:

.

August 13-16, 1974

Dates of Previous Inspection:

July 11, 12, 16 and 17, 1974

.

Reporting Inspector.:

k

.,b,,,wmL

(/ g

.7 j,

'

/ Date

R. L. Spessard, Reactor Inspector

Accompanying Inspectors:

imt.

Date

Date

Date

.

.

Date

.

,

Other Accompanying Personnel:

NONE

Date

G-

1566

298

.

Reviewed By:

(,

dt

%gy

A. 3. Davis, Senior Reactor InspecLur

'D<2 L e

Reactor Operations Branch

79111 TO 092

~

._

-.

-

,

.

SUFSL\\RY OF FIiDI:!GS

Enforcement Action

A.

Violations

Contrary to the requirements of 10 CFR 50, Appendix B, Criterion

XII and the licensee's QA Plan for Startup and Test,Section XII,

a Brush Recorder used during the Generator Trip Test and other

earlier Initial Startup Tests had not been properly controlled and

recalibrated at the specified frequency. - (Details, Paragraph 3.e)

B.

Safety

.

None Identified

Licensee Action on Previous 1v Identified Enforcement Items

A.

The licensee's corrective action as specified in his letter of

response dated July 5,1974 to the violations identified in R0:I

' '

letter dated June 12, 1974 and Report 50-289/74-23 was reviewed

(

/-~

during this inspection and a previous inspection.

These items are

closed.

(Details, Paragraph 6.a&b)

B.

The licensee's corrective action as specified in his letter of

response dated July 15, 1974 to the violations identified in R0:I

letter dated June 21, 1974 and Report 50-289/74-25 was reviewed

during this inspection and a previous inspection.

These items

.

are closed.

(Details, Paragraph 6.c&d)

,

Design Changes

A.

Turbine Trip Test at 100% rated ocwer (TP 800/14)

In accordance with the provisions of 10 CFR 50.59 and the Technical

Specifications, the licensee intends to delete this test from the

Initial Startup Test Program. (Details, Paragraph 5)~

_ Unusual Occurrences

None Identified

1566

299

Other Sienificant Findines

A.

Current

G, ~

1.

Sigt ificant personnel changes have occurred in the Met Ed site

l

orga:.ization.

(Details, Paragraph 2)

.

.

_ - -

.

.

.

,

~

7

s

.

-

t

-2-

.

'

2.

The Gen:rator Trip Test from 100%- rated power was performed

during this R0 inspection, and this test was witnessed by R0:I.

Following this test, the plant was cooled down to begin a 2

week scheduled maintenance outage.

(Details, Paragraph 3)

3.

Initial startup testing through the 76% FP plateau has been com-

pleted, and the data has been evaluated and accepted by the

licensee.

R0:I review of this data and the licensee's evaluation

disclosed no deficiencies.

.

(Details, Paragraph 4)

4.

Initial startup testing at the 100% FP plateau has been com-

pleted with the exception of a few tests that are to be completed

at 100% FP steady state conditions; however, the data has not

been reviewed and accepted by the licensee.

RO:I review of a

part of this data disclosed no major deficiencies relative to

demonstration of the desired performance criteria and/or predicted

performance.

(Details, Paragraph.4)

5.

Licensee. action on previously identified open items was reviewed,

and several of these items were closed.

(Details, Paragraph 6~.e-h)

B.

Status of Previousiv Reported Unresolved Items

Not inspected.

Management Interview

An exit interview was held onsite on August 16, 1974 at the conclusion of

the inspection with Mr. J. Herbein, Station Superintendent and Mr. J. Colitz,

Unit Superintendent.

The following summarizes the items discussed:

A.

The Generator Trip Test including the apparent violation.

(De tails ,

Paragraph 3)

B.

Initial Startup Test results (Details, Paragraph 4)

C.

Deletion of the Turbine Trip Test at 100% rated powe'r from the Initial

Startup Test Program.

(Details, Paragraph 5)

D.

Licensee action on previously identified enforcement and open items.

(Details, Paragraph 6)

1566

300

t

I-

-

..-.

.

.

.

- - . .

.-

,

_

_.-.

-

'

.

.

.

.

(

.

tu

.

{}

-

DETAILS

1.

Persons Contacted

Metropolitan Edison Comnany

,

Mr. J. Herbein, Station Superintendent

Mr. J. Colitz, Unit Superintendent

Mr._J. O'Hanlon, Nuclear Engineer

Mr. C. Hartman, Electrical Et?,ineer

Mr. B. Getty, Mechanical Enginser

Mr. R. Harper, Instrument Foreman

Mr. D. Shovlin, Supervisor of Maintenance

Dr. T. Baer, Station Engineer (Acting Technical Supervisor, Chemistry)

Mr. R. Miller, Test Coordinator

Mr. W. Poyck, Staff Specialist

Ms. C. Nixdorf, Office Supervisor

Mr. J. Chwastyk, Shif t Supervisor

Mr. G. Wallace, Shif t Supervisor

Mr. M. Ross, Shift Supervisor

-

I

h. 3

Mr. B. Smith, Shif t Foreman

Mr. B. Mehler, Control Room Operator

General Public Utilities Service Corporation

'

Mr. J. Barton, Startup and Test Manager

Mr. G. Miller, Test Superintendent

Mr. R. Toole, Assistant Test Superintendent

-

Mr. C. Gatto, Shif t Test Engineer

Mr. I. Porter, Shif t Test Engineer

Mr. S. Poje, Shif t Test Engineer

Mr. T. Hawkins, Shift Test Engineer

.

Babcock . nd Wilcox Nuclear Services

Mr. W. Raymond, Shift Data Analyst

2.

Personnel Chances

A licensee representative informed the inspector of the following

changes in the site organization:

a.

Mr. J. Colitz, formerly Station Engineer, was promoted to Jnit

Superintendent on August 1, 1974.

9-

b.

Mr. K. Beale, formerly Radiation Protection Foreman, was pro-

moted to Radiation Protection Supervisor en August 1, 1974.

1566

301

--

1_

_-

4

-

.

.

w

f

-4-

.

Mr. G. Miller, presently GPU Test Superintendent, has been

c.

hired as Unit Superintendent to become effective when Unit I

is declared commercial.

d.

Dr. T. Baer, presently Station Engineer and Acting Technical

Supervisor, Chemistry, has-been promoted to a position in the

Met Ed corporate office to become effective on or about

September 1,1974.

3.

Inspector's Witnessing of the Generator Trin Test

During this RO inspection the inspector witnessed the preparation

for and the conduct of the Generator Trip Test (TP 800/34) which

occurred on August 13, 1974,.

The following items represent areas

observed and specific comments concerning them.

Correct procedure and revision in use:

The Official Field Copy

a.

of TP 800/34 had all revisions included.

b.

Minimum crew requirements:

The normal shift complement supple-

r

I

O '3

mented by an additional Control Room Operator performed the test.

Additionally, a second shift supervisor was present to assist

if required.

Personnel required to operate data recorders,

as

specified in TP 800/34, were at their assigned stations.

Repre-

sentatives from GAI were present to make steca hammer transient

mearurements during the trip and to inspect the results of

transient loading on piping and supports due to the trip.

c.

Test prerequisites met:

The inspector observed that the_ plant

.

'

was operating at 98% of rated power (TP 800/34 requirement was

100% + 0%, -5% of rated power) and that the other prerequisites

in Sections 4 and 7 of TP 800/34 were signed off prior to test

performance.

d.

Proper plant systems in service:

The inspector observed that

reactor coolant pressure control was in automatic controlling

pressure at 2155 25 psig and that the narrow range pressure

channel imput to the pressurizer spray valve, elec trema tic

relief valve, and heater control circuit was the one hooked

up to the brush recorder and reactimeter. Additionally, the

innpector observed that the other prerequisite systea conditions

in Section 8 of TP 800/34 were signed off prior to test per-

fo rmance.

e.

Special Test equipment: The inspector observed that the re-

O,

'

actimeter, 3 brush recorders and a multipoint recorder, as re-

1566

302

_

. _ _ _ _

.-

-

--

.

.

.

_

p

.,

(

-S-

.

'

quired by TP 800/34, plus 5 brush recorders to monitor the

Integrated Control System (ICS) were present and that the input

signals required by TP 800/34 were connected and identified.

Control of this test equipment in accordance with the require-

ments of Test Instruction No. 19 (TI-19) was reviewed on a

sampling basis by the inspector.

This instruction requires in

part that test equipment used during initial startup testing be

calibrated and recalibrated at specified frequencies in accord-

ance with Quality Control Procedures QC-13 and QC-13-2 and that

on the first working day of each month the user and Quality

Control be notified of the test equipment which requires recali-

bration during that month.

The calibration label attached to

each brush recorder (II.-19 requirement) was observed by the

inspector. This observation revealed that one of the three

brush recorders required by TP 800/34, designated brush recorder

No.1, had not been recalibrated on or before its calibration

due date as required by T1-19.

This recorder had been calibrated

on December 27, 1973 and the calibration due date was June 27, 1974.

According to licensee representatives this recorder had also been

,

I

b'

used on several other initial startup tests.

The inspector also

-

observed that one of the five brush recorders monitoring ICS

response, which was not a part of this test, had also not been

recalibrated within the required frequency.

The inspector observed that each brush recorder had been field

calibrated (each input channel was subjected to known input voltages

to verify alignment) by Met Ed instrument personnel; however, this

calibration technique did not meet the full requirements of TI-19,

e. g. calibration of time response.

The licensee representative

indicated that this type of calibration was done each time a brush

recorder was to be used. Prior to test performance and in the

presence of the inspector, the representatives performed a com-

parison check of time response between brush recorder No.

I and

No. 2 (required by TP 800/34), and they determined the time re-

sponse of the recorders to be essentially the same.

The repre-

sentatives determined that brush recorder No. 1 was suitable for

use, and s recalibration of this recorder pursuant to TI-19 was

planned following test performance.

According to the represente -

tives, the results of the recalibration will be evaluated to

assure that data obtained by this recorder is valid.

Failure to properly control and recalibrate at the specified

frequency brush recorder No. 1 is an apparent violation of 10 CFR 50, Appendix B, Criterion XII which states in part, " Measures shall

{

}

be established to assure. . . instruments. . .used in activities affecting

quality are controlled, calibrated, and adjusted at specified periods

to maintain accuracy within necessary limits." This is also an

1566

303

-

c

_ _ . _ _ . -

--

._.

-_

___

_

.

.

'

.

!

s

1 ,i

.,

.

apparent violation of the licensee's QA Plan for Startup and

,

-

Test,Section XII, which states in part, " Test equipment used

-

during. . .startup tests is controlled and calibrated in accord-

ance with TI-19."

f.

Transient test data equipment calibration to a common time base:

The inspector observed that all recorders were to be started

by a common switch and common event markers were available for

time correlation. Additionally, a final check of recorders

and signal response was made before the countdown began to

'initiate the test.

.

g.

Test performed as required by procedure:

The test was observed

to be performed in accordance with the test procedure which

included portions of thd plant emergency procedure for load re-

jection and in accordance with Emergency Procedure EP 1202-3

Turbine Trip.

h.

Crew response:

Crew actions appeared to be correct and timely

during the performance of the test.

About four seconds following

the generator trip, a reactor trip / turbine trip occurred as a

9,_)

result of high reactor coolant pressure.

The plant is designed

to withstand a 100% load rejection without a reactor trip; however,

this condition was recognized by the crew, and EP 1202-3 Turbine

Trip was followed along with the applicable portions of TP 800/34

to control plant conditions.

1.

Quick summary analysis made to assure proper plant response to

the test:

Following the generator trip, the main turbine control

valves and intercept valves closed and the main turbine bypass

.

valves and the main steam safety valves opened.

Reactor run-

back was initiated; however, the reactor tripped which init:iated

a turbine trip.

This resulted in closure of the main and inter-

mediate turbine stop valves.

The reactor coolant pressure /

temperature relationship, pressurizer level, steam generator levels

main steam pressure, and feedwater temperature were controlled

,

within limits.

The turbine did not exceed overspeed limits.

.

j.

All data is collected for final analysis by the proper personnel:

Required recorder traces and data sheets were obtained and evalu-

ation of the results was initiated.

k.

Test results indicate acceptance criteria has been met:

Reactor

coolant pressure was observed by the inspector to stay within

0

-

1566 304

- -

- - -- -

,

.

i

1

-

.

.

.

~()

w,

'

-7-

,

l

.

f

I

the protection system envelope (Technical Specification Figure

2.3-1) while the reactor was operating, and a reactor trip was

initiated by channels A and C when the reactor coolant high

pressure trip set point (2355 psig) was reached.

The maximum

pressures recorded ranged between 2320-2350 psig.

The minimum

pressures recorded ranged between 1700-1750 psig and occurred

'

about 68 seconds after the reactor trip.

Reactor coolant pres-

sure was returned to normal operating conditions about 10 min-

.utes after the test was initiated.

A review of the raw test data indicated that the test acceptance

criteria had been met or that where deviations occurred these

could be justified on the basis of a reactor trip / turbine trip

occurring.

The turbine overspeed limit (1980 rpm) was not ex-

ceeded; ma).imum speed recorded was 1885 rpm and the speed was

decreasing when the turbine trip occurred.

No fission product

activity increase was observed in-the reactor coolant following

the test.

(~

4.

Inspector's Review of Initial Startup Test Data

I

I-)

a.

Detailed Review

The inspector conducted a detailed review of the completed /

partially completed procedures (Official Field Copy) listed

below.

Additionally, the Partial Test Summary for these

tests, as accepted by the licensee, was also reviewed and is

listed below, where appropriate.

No deficiencies were identi-

"

fied, and the inspector's review included the following:

Data sheets available and completed (at least 10% sampling

basis); raw data converted to test data; test exceptions and

deficiencies identified; corrective action performed; accep-

tance criteria verified by licensee; test analysis reviewed by

the appropriate persons; and inspector's verification that test

results demonstrate the desired performance criteria and/or

predicted results.

Additionally, Tk'G Meeting minutes fer the

period August 1-9, 1974 (Meetings 123-126) were' reviewed.

.

(1) TP 800/2 Nuclear Instrumentation Calibration at Power

Test is complete and included testing at the 76% and 100%

FP test plateaus.

Additionally, a Partial Test Summary for

the 76% FP test plateau was approved by the licensee prior

to power escalation to the next higher test plateau.

Final

9~

review and acceptance of test data by the licensee was not

completed, and this remains as an open item.

!

i566

305

'

_

.-

_ - _ - - .

- - - - -

-

.

,

(

'

-

-8-

~

.

f

(2) TP 800/5 Reactivity Coefficients at Power

Test is complete and included testing at the 76% and 100%

FP test plateaus.

Additionally, a Partial Test Summary for

the 76% FP test plateau was approved by the licensee prior

to power escalation to,the next higher test plateau.

On the

basis of testing at Oconne 2 and at TMI-l (40% FP test data),

B&W provided new design values for the Power Doppler coeffi-

cient for 76% and 100% FP (TCN-1 to Tl 800/5 dated July 26,

1974). Data obtained indicated close agreement with the new

design values of -8,5 PCM/% FP at 76% FP and -7.3 PCM/% FP

at 100% FP and met the acceptance criteria.

The Temperature

Coefficient was determined to be -2.51 PC'4/ F at 76% FP (1120

ppm Reactor Coolant boron concentration) and -3.29 PCM/0F at

100% FP (1092 ppm Reactor Coolant boren concentration), and

these values met the acceptance criteria.

Final review and

acceptance of test data by the licensee was not completed,

and this remains as an open item.

(3) TP 800/11 Core Power Distribution

Test is complete and included testing at the 76% and 100% FP

test plateaus. Additionally, a Partial Test Summary for the

76% FP test plateau was approved by the licensee prior to

power escalation to the next higher test plateau.

Final re-

,

!

!

view and acceptance of test data by the licensee was not ccm-

pleted, and this remains as an open item.

(4) TP 800/18 Power Imbalcnce Detector Correlation Test

'

Test is complete and the results were accepted by the licensee

,

l

prior to power escalation from the 76% to the 100% FP test

i

plateau.

(5) TP 800/20 Rod Reactivity North Measurement

Test is complete and included testing at the 76% and 100% FP

'

test plateaus. Additionally, a Partial Test Summary for the

76% FP test plateau was approved by the licensee prior to

power escalation to the next higher test plateau.

Final

review and acceptancc. of test data by the licensee was not

ccmpleted, and this remains as an open item.

(6) TP 800/21 Unit Startup and Power Escalation Test

_

Test is partially complete and included testing from 76% to

100% FP.

Additionally, a Partial Test Summary for the 76%

t

1566

306

t

,

-

t

.

,

.

( ~)

.

l

}

-9-

'

.

FP test plateau was approved by the licensee prior to

power escalation to the next higher test plateau.

The

inspector also verified the following by review of

plant records and discussions with licensee representa-

tives:

.

(a) Licensee evaluated the data obtained at the 76% FP

test plateau and authorized operation at the next

higher power level.

,

(b) Licensee reset the high flux ' trips as' required by

TP 800/21 prior to power escalation to the next

higher test plateau.

(c) Licensee performed core and plant surveys to assure

safe operation during the increase of power level

and arrival at the new power level.

(d) Licensee determined control rod configuration and

necessary boron concentration prior to increasing

,

. .)

power above 80% FP and positioned the control rods

during escalation to 100% FP in order to meet con-

trol rod withdrawal limits of Technical Specifica-

tion Figure 3.5-2A.

-

(e) Licensee verified operability of incore detectors

prior to escalation above 80% FP as required by

Technical Specification 3.5.4.

.

.

l

(f) Licensee performed a reactivity balance prior to

I

escalation above 80% FP to verify the shutdown

I.

margin met Technical Specification 3.5.2.1.

I

i'

(g) Licensee verified xenon reactivity met Technical Specification 3.5.2.5.c prior to escalation above

82.5% FP.

(h) Licensee adjusted and calibrated the Reactor Pro-

tection System Flow Summer in accordance with Work

Request No. 3409 during escalation from 80% to 100%

FP, as required by the TWG for power escalation

testing above 76% FP.

i

.

Final review and acceptance of test data by the licensee was

not completed

(test has not been completed), and this remains

-

'

as an open item.

I566

307

_

,

_

._

_ . _ - _ _

.

_

.

.

.

.

-

,

f 's

<

.

-

.

.

10_

_

{

I

.

.

'b.

Verification

The inspector verified by review of the Official Field Copy

of the completed test procedure or the partially completed

test procedure with corresponding Partial Test Summary, as

appropriate and by review T;.'G Meeting minutes that the test

results for the procedures listed belcw had been evaluated

by the licensee and that he had determined them to be accep-

table and/or had taken proper corrective action on non-

' acceptable findings.

No deficiencies were identified, and

the inspector's observations are included, where appropriate.

(1) TP 500/3 Initial Radiochemistry Test

Test is complete and included testing from 76% to 100%

FP.

Additionally, a Partial Test Summary for the 76% FP

test plateau was approved by the licensee prior to power

escalation to the next higher test plateau.

Final review

and acceptance of test data by the licensee was not cca-

pleted, and this remains as an open item.

1

'

(2) TP 800/8 ICS Tuning at Power

Test is complete and included testing from 76% to 100%

l

FP.

Additionally, a Partial Test Summary for the 76% FP

'

test plateau was approved by the licensee prior to power

escalation to the next higher test plateau.

Final review

and acceptance of test data by the licensee was not com-

pleted, and this remains as an open item.

,

,

(3) TP 800/14 Turbine / Reactor Trip

Test is partially complete.

Test results for the Turbine

Trip at 30% FP (Report 50-289/74-28, Details 3.b. (2)(b)) were

reviewed and determined to be acceptable by the licensee;

however, the results were not approved because a Main Steam

'

Safety Valve (MS-V17D) lifted below its setpoint (1050 10.5

psig).

Prior to this test all of these valves had been

checked and reset i.n accordance with TP 271/4 Main and

Auxiliary Steam System Functional Test because of premature

lifting experienced during the Reactor Trip at 40% (Report

50-289/74-28, Details'2.a.).

The results of TP 271/4 which

included resetting of valve MS-V17D (af ter the Turbine Trip

at 30% FP) were approved by the licensce.

The cause of the

O_

premature lif t is still being reviewed by the licensee, and

this item remains open pending final resolution by the

-

licensee.

The licensee cencluded on the basis of testing

(Reactor Trip at 40% FP, Turbine Trips at 30% and 76% FP,

1566

308

_we

  1. '

,

-

__

_

_

.

.

i%

\\

'

.

-11-

.

1*

and retesting per TP 271/4) that conditions were safe for

increasing reactor power from 76% to 100% FP.

(4) TP 800/23 Unit Lead Transient Test

Testing at the 76% FP test plateau was not completed prior

to escalation to the 100% FP test plateau because of power

reduction cauced by condenser leakage and generator bearing

vibration.

For these reasons and on the basis of satis-

factory performance of the ICS, the licensee approved the

.

postponing of this testing until af ter ccmpletion of steady

state testing at 100% FP and rescheduled this testing in

conjunction with the transient testing to be done at the

100% FP test plateau.

Test is complete; however, final

review and acceptan'ce of test data by the licensee was not

completed, and this re=ains as an open. item.

(5) TP 800/31 Pseudo Dropped Rod

Test is complete, and the results were accepted by the

{

licensee prior to power escalation frca the 76% to the

100% FP test plateau.

(6) TP 800/35 Effluen and Effluent Monitoring System Test

I

i

!

Test has not been conducted because insufficient radwaste

activity (liquid and gas) had been generated to =cet test

prerequisites.

The Partial Test Sumniacy for the 76% FP

test plateau was approved by tha licensee an this basis

-

prior to pcwcr escalation to the next higher test plateau.

Completion of this test and acceptance of the results

,

j

by the licere ce remain as open items.

c.

Other Test Results

The inspectof observed during review of TWG Mceting minutes for

the period August 1-9,1974 (Meetings 123-126) and Official

Field Copies of Partial Test Summa ries for the 76% FP test

plateau that the recults of the tests listed b.: low had been

l

evaluated by the licensee prior te power escalction to the

next higher test plateau.

Additic nally, results of completed

l

tests that were accepted by the 1:censee are ideatified, as

I

appropriate.

(1) TP 800/7 Feed System Operatici. and Testing

9

(2) TP 800/9 Turbine Cencrator Op aration and Testing

(3) TP 800/12 Unit Load Steady State Test

(4) TP 800/24 Incore Detector Testing (test complete and results

accepted by the licensee)

(5) TP 800/30 Power Escalation Checkpoints

-

1566

307

-

.

.

.

~

.

(3

-

-12-

'

ll

.

I

5.

Design Change

I

i

The licensee's Power Escalation Test Program, as described in

Table 13-4 of the FSAR, includes a reactor trip at 40% FP, turbinc

l

trips at 30% FP and 100% FP, and a Generator Trip at 100% FP.

The

i

licensee plans to delete the Terbine Trip at 100% FP from the Power

Escalation Test Program pursuant to the requirements of 10 CFR 50.59.

i

i

The inspector reviewed the licensee's written initial safety

evaluation for this design change, and he observed that this evalua-

tion had been reviewed by the PORC pursuant to Technical Specifica-

tion 6.1.I.l.d.2), had been approved by the Station Superintendent

pursuant to Technical Specification 6.1.D.2, and had been sent to

the Manager-Generation Engineering for review by the Met Ed Corporate

Technical Support Staff pursuant to Technical Specification 6.1.I.2.b.1).

Review by the Mat Ed Corporate Technical Support Staff to verify that

an unreviewed safety question was not involved had not been ecmpleted,

and this remains as an open item.

The licensee's written safety evaluation included the following:

S(;

Consequences Related to Plant Safety - Plant response to various

a.

planned system transients (reactor trip at 40% FP and turbine

trip at 30% FP) and unplanned system transients (reactor trip at

100% FP and turbine trip at 76% FP) was reviewed and determined

to be acceptable.

Additionally, data obtained for turbine trips

at 30% and 76% FP was extrapolated to 100% FP, and the projected

response of safety related parameters was deternined to be

acceptable.

The planned generator trip at 100% FP was viewed by

the licensee as providing additional assurance of the unit's

ability to withstand transients.

b.

Comparison of Turbine and Gernerator Trip - Plant response (safety

related parameters) to either trip was determined to be the same

due to plant design with the exception of the potential for turbine

overspeed following a generator trip.

The planned generator trip

at 100% FP was viewed by the licensee as accomplishing the same

requirements as a turbine trip at 100% FP plus demonstrating the

turbine does not overspeed.

6.

Licensee Action on Previously Identified Enforcement and Open Items

a.

Daily Reactor Coolant System leakage evaluations not performed

O

Reference: (1) RO:I letter dated June 12, 1974 and Report 50-289/

74-23, Details 10.

(2) Met Ed letter dated July 5, 1974

1566

310

.

-13-

.

Based on a revieu of facility records and discussions with

licensee representatives, the inspector determined that licensed

personnel had been reinstructed concerning this requirement

by the Supervisor of Operations and that more strict adminis-

trative control of surveillance test documentation had been

achieved.

During a review of completed surveillance tests

(1303-1.1) for the period June 1 - August 13, 1974, the inspector

observed that this test was being conducted on each shift (3

times per day), whereas Technical Specification Table 4.1-2

specifies a daily test. This item is closed.

b.

Improper change made to an initial startup procedure (TP 330/5)

Reference: (1) R0:I letter dated June 12, 1974 and Report 50-289/

74-23, Def. ails 20.

(2) Met Ed letter dated July 5, 1974

Based on a review of facility recor'ds and discussions with

licensee representatives, the inspeator determined that Met Ed

operations and CPU test personnel had been reinstructed on the

-)

proper method of affecting procedure changes by the Station

Superintendent and the CPU Assistant Test Superintendent.

Addi-

tionally, Superintendent's Operation Memo No. 17, dated June 3,

l

1974 stressed the requirements concerning procedures and pro-

{

cedure changes.

The preparation, approval, issuance and use of TCN-2 to TP 330/5

was reviewed during a previous RO inspection (Report 50-289/

,

74-25, Details 3.b. (1) (c)).

,

The licensee had not prepared a procedure for repatching control

rods from one group to another.

According to a licensee repre-

sentative, this procedure is to be prepared, approved and issued

prior to performing the next scheduled repatch of the control rods

and is to be similar to TCN-2 to TP 330/5.

The control rods have

not been repatched since the completion of TP 330/5, and there-

j

fore a procedure has not been required.

-

!

This item is closed; hauever, the issuance of a procedure for

!

repatching control rods 'will be verified during a subsequent R0

.-l

inspection.

.

Superseded procedures used to align safety related systems during

c.

preparations for initial criticality

9

1566

311

-

--

.

,

.

,s

'-

.

-14-

-

9

.

Reference: (1) RO:I letter dated June 21, 1974 and Report 50-289/

74-25, Details 13.e. (1) and (2) .

(2) Met Ed letter dated July 15, 1974

The actions taken by the licensee prior to beginning the approach

to initial criticality were reviewed during a previous R0 inspec-

tion (Report 50-2S9/74-25, Details 13.e)

.To avoid future violations of this type, the licensee issued Opera-

tions Memo No. 27 which defined responsibilities for maintaining

the procedure files and reiterated clic importance of assuring

only current procedures are used.

This memo also requires weekly

audit of these files. The inspector observed the current pro-

cedure index was kept with the precedure files in the Contrcl Room,

and an audit of these files (20 procedures involving safety re-

lated systems selected at random) by the inspector disclosed

no deficiencies.

According to licensee representatives, these

files are being continually maintained as revised procedures are

issued and the audits are being accomplished more frequently

f 3

than weekly,

O s-

This item is closed.

d.

Procedure containing unauthorized changes used to align a safety

related system during preparations for initial criticality

Reference: (1) RO:I letter dated June 21, 1974 and Report 50-289/

74-25, Details 13.c.(3).

(2) Met Ed letter dated July 15, 1974

,

.

The actions taken by the licensee prior to beginning the approach

to initial criticality were reviewed during a previous RO inspec-

tion (Report 50-289/74-25, Details 13.c)

Licensee records indicated that the TCN requested had been approved

'

on May 24, 1974; however, due to a backlog of administrative

work at that time the TCN had not been issued. ' A permanent change

request (PCR 74-105), which covered the changes involved, was

approved and issued on July 1, 1974.

Based on discussions with licensee representatives, the inspector

determined that shif t super /isors and reactor operators were

instructed on the proper method of making changes to procedures

!

by the Supervisor of Operations.

'

This items is closed.

1566

312

_

_

.

.

.

-15-

,

I

Licensee guidance to emplo'ees on practices to be followed in

f

c.

evaluating a reactor coolant leak

Reference:

(1) Report 50-289/74-23, Details 17

The inspector reviewed plan't records and had discussions with

licensee representatives to determine what action had been taken

by the licensee since this item was brought to his attention.

' The inspector observed the following actions had been taken:

(1) The PORC (Meeting 233) recommended to the Station Superintend-

ent that when reactor coolant leakage is identified evaluations

be made by the Shif t Supervisor and one of the following -

Station Superintendent, Station Engineer or Supervisor of

Operations and that the evaluation be documented in the Shift

Supervisor's Log Book.

The Station Superintendent accepted

the PORC's recommendation and had this guidance instituted.

The inspector observed the documentation of one such evalua-

tion ~ and had no questions on this matter.

I(

I

(2) Chemistry Standing Order 13 was issued which requires tech-

nicians to inspect designated areas at specified frequencies

for reactor coolant leakage, to report leakage identified to

the Shift Supervisor, and to document the leakage in the

Chemistrf' Supervisor's Log Ecok.

(3) Excessive reactor coolant leakage identified during the per-

formance Surveillance Procedure 1301-1.1 (Daily Leak Rate

.

Evaluation) is investigated, evaluated, and documented in

accordance with this procedure.

Additionally, the results of

these tests are reviewed and evaluated in the same manner as

other surveillance test results, ie, in accordance with AP 1010.

This item is closed.

f.

Fluid Block System

References:

(1) Report 50-289/74-18, Details 3.a.(6)

(2) Report 50-289/74-23, Details 7.b. (2)

The licensee submitted FSAR A.endments 48 and 49 dated May 15, 1974

and August 1, 1974, respectively, to update the description of this

system based on results obtained during preoperational testing.

This item is closed.

1566

313

..

_

_

_

_

'

s

i

n

e

.

T

'

t.

-16-

.

1

g.

Reactor Building Fan Motor Malfunction

Reference;

Report 50-289/74-18, Details 3.a.(7)

The third reactor building fan (AH-ElC) was returned to service

on August 2, 1974.

The motor was installed and post maintenance

testing performed in accordance with a properly approved Work

Request (WR 2718).

The inspector observed that the post maintenance

test requirements were consistent with the initial test requirements

' performed during preoperational testing (TP 250/2 Testing and Check-

ing of Mechanical and Electrical Equipment) and that no deficiencies

had been identified by the licensee during post naintenance testing.

This item is closed.

'

h.

Apparent weakness in the licensee 's document control system

Reference: Report 50-289/74-23, Details 8

The inspector had discussions with licensee representatives to

,

q

j

determine what action had been taken by the licensee since this

matter had been brought to his attention.

The inspector was in-

formed of the following:

(1) The Aperature Card File had received a 100% review, had been

updated following this review, and has been maintained current

as drawing revisions are processed in accordance with AP 1001.

(2) Each controlled print is audited every 3 months following re-

ceipt of the updated computer printout.

(3) Priority attention has been given to prompt distribution of

revised drawings and aperature cards in accordance with AP 1001.

Additionally, the inspector observed a package of updated drawings

that had been recently received and was being processed for distri-

bution.

The inspector had no questions on this matter.

The inspector informed. the licensee representatives that it appeared

the licensee's system provided reasonable assurance that the latest

approved drawing revisions would be promptly distr:buted.

However,

the inspector expressed concern abcut an apparent usakness in the

licensee's program.

For example, an approved pim modification

could be made in accordance with a Problem Report (PR) or GAI Field

9

Questionnaire (STQ), and in these cases a long period of time could

elapse between completion of the modification and revision / distribution

of the af fected printc; therefore, during this

1566

314

.

-

-.

..

_._-

,

.

_ .

. _ . . _

_

_

t

.

.

..

,

-17-

,

..

I

period of tire, the as-built system would not be correctly described

by the controlled prints.

The inspector observed that this con-

dition does not occur for approved plant modification made in

accordance with a Field Change Request (FCR), as revised drawings

are issued with the approved FCR.

The licensee representative's acknowledged the inspector's concern

and indicated that it would be evaluated.

-This matter is considered an open item.

.

.

.

I

E

1566

315

.

-

.

.

!

I

'

.

_

_