ML19253B674
| ML19253B674 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/21/1974 |
| From: | Mccabe E, Panzarino N, Ruhlman W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19253B667 | List: |
| References | |
| 50-289-74-32, NUDOCS 7910160757 | |
| Download: ML19253B674 (22) | |
See also: IR 05000289/1974032
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U.S. AT0!!IC ENERGY C0!R!ISSION
IIIRECTORATE OF REGULATORY OPERATIONS
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REGION I
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RO Inspection Report No:
50-289/74-32
Docket No:
50-289
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Licensee:
Metropolitan Edison Company
License No:
._ Priority:
C
Three Mile Island Unit 1
Category:
Location:
Middletown, Pennsylvania
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Typ'e of Licensee:
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Type of Inspection:
Routine, Announced
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Dates of Inspection:
October 7-9, 1974
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Octob'er 7-9, 1974
T tes of Previous Inspection:
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Reporting Inspector.:
[
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Date
W. A. Ruhlman, Reactor Ingpector
Accompanying Inspectors:
f t /L.M (
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N. Panzarino, hadiation Specialist
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None
Other Accompanying Personnel:
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Reviewed By:
(
t, . c. McLace, Jr., dentor neactor inspector
Date
Nuclear Support Section, Reactor Operations Branch
7910.160787
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SUMMARY OF FINDINGS
Enforcement Action
A.
Violations
1.
The licensee had failed to instruct all individuals working
in or frequenting any portion of a restricted area in all
of the specific items required by 10 CFR 19.12.
(Details 2.a)
2.
The licensee discovered that the Sodium Hydroxide Tank con-
tained about four percent (677 pounds) more sodium hydroxide
(NaOH) than al. owed by the Technical Specifications Section 3.3.1.3.b.
(A0 74-17, letter to RO:I dated Septe=ber 30,
1974)
The corrective measures were reviewed during this
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inspection. No additional response is required.
(Details 7.b)
3.
The licensee's procedure 1202-6, LOSS OF RC/RCS PRESSURE,
failed to provide appropriate quantitative or qualitative
acceptance criteria for the operator to determine when suffi-
cent sodium hydroxide had been pumped into the containment
following the postulated loss of pressure accident covered
by the procedure, violating both Criterion V, Appendix B,
10 CFR 50 and Section V of the licensce's Operational Quality
Assurance Program included as Appendix 1A in the facility
FSAR.
(Details 8)
Licensee Action en Previous 1v Identified Enforcement Items
The licensee had taken the corrective actions specified in his response
(Letter to RO:I dated October 1,1974) to the apparent violation des-
cribed (Letter RO:I to Licensee dated September 9, 1974) which trans-
mitted Inspection Report 50-289/74-29.
(Details 9)
.
Unusual Occurrences
An unplanned radioactive gas release occurred while the inspec or was
on-site.
See Report 50-289/74-31 for further information.
Other Significant Findings
A.
~urrent Findinge
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1.
Non-Deficient Items
The following were inspected with no deficiencies, unresolved
or open items identified.
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a.
First Aid Training.
(Details 2.e. (1))
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b.
Fire Fighting fraining.
(Details 2.e. (2))
c.
Maintenance Personnel, Job Related Health Physics
Training.
(Details 3.c)
d.
Maintenance Personnel, On-the-Job Training.
(Details 3.d)
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Maintenance Personnel, Records.
(Details 3.e)
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f.
Welder Qualification / Certification Training.
(Details 4)
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g.
Replacement Training for Licensed Operators.
(Details 5)
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h.
Licensed Operator Requalification, Completed Program Items.
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(Details 6.a)
1.
Plant Tour.
(Details 12)
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2.
Unresolved Items
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The following items are unresolved pending formalization of
the licensee's proposed actions and an ex post facto reviev
by RO:I.
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a.
General Employee, Facility Access Control and Security
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Training.
(Details 2.c)
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b.
General Employee, Industrial Health and Safety Training.
(Details 2.e)
c.
Maintenance Personnel, Procedure Review / Indoctrination.
(Details 3.b)
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3.
Open Items
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The following items are open. The licensee's proposed actions
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were defined for each item; but, since not yet required or
completed, the necessary RO:I review and evaluation could not
be accomplished.
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General Employee Facility Contingency Procedure Training.
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a.
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(Details 2.b)
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b.
General Employee Quality Assurance Training.
(Letails 2.d)
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Maintenance Personnel Quality Assurance Training.
c.
(Details 3.a)
d.
Licensed Operator Requalification, Incomplete Program
Items.
(Details 6.b)
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e.
Control Switch Investigation.
(Details 11)
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B.
Status of Previous Items
1.
Resolved Items
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The licensee had completed the actions required to resolve
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the following.
The inspector had no further questions on
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these items.
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Certain review require =ents were lacking in the Quality
a.
Assurance Program as noted in Detail 2 of Report 50-289/
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74-14. The program has been revised to include the
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necessary requirements, and this item is resolved.
(Details 10.a)
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b.
Report 50-289/74-29, Details 6.b. identified an open
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item with the licensee's control of prints.
This item
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has been resolved by irstituting new administrative
controls and systems.
(Details 10.c)
2.
Open Items
Although the licensee's actions to resolve the $tems had been
initiated, RO:I review indicates that additional information
is needed; therefore, these itees remain open.
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A concern with respect to the manner of handling and
a.
analyzing certain chemical samples was identified as an
open item in Detail 5 of Report 50-289/74-24.
The
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licensee's Chemistry Procedure 1972 addresses part of
the concerns identified in the report, but additional
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information is needed.
(Details 10.b)
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b.
All of the permanent corrective actions.t.pecified in
A0 74-15 had not yet been completed.
The incomplete
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item is open.
(Detalle 7.a)
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Management Interview
A combined management exit interview was held at the site on October 9,
1974 for inspections 50-289/74-31 and 74-32 with the following licensee
attendees.
Metropolitan Edison Company
NW. J. G. Herbein, Station Superintendent
Mr. J. J. Colitz, Unit 1 Superintendent
Mr . J. R. Floyd, Supervisor of Operations - Unit 1
Mr. W. E. P6tts, Supervisor - Quality Control
Mr. J. L. Seelinger, Supervisor of Training
Mr. M.~R. Buring, Health Physicist (Reading Office)
Mr. D. C. Orlandi, Lead Instrument and Control Engineer
Porter-Gertz Consultant, Inc.
Mr. S. W. Porter, Jr. , Consultant
The following su=marizes the items discussed relevant to the inspection
documented in this report.
A.
General Employee, Radiological Health and Safety Training.
(Details 2.a)
B.
General Employee, Facility Contingency Procedure Training.
(Details 2.b)
C.
General Employee, Facility Access Control and Security Training.
(Details 2.c)
D.
General Employee, Quality Assurance Training.
(Details 2.d)
E.
General Employee, T.ndustrial Health and Safety Training.
(Details 2.e)
F.
Maintenance Personnel, Quality Assurance Training.
(Details 3.a)
G.
Maintenance Personnel, Procedure Review / Indoctrination.
(Details 3.b)
H.
Maintenance Personnel, Job Related Health Physics Training.
(Details 3.c)
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Maintenance Personnel, On-the-Job Training.
(Details 3.d)
J.
Maintenance Personnel, Records.
(Details 3.e)
K.
Welder Qualification / Certification Training.
(Details 4)
L.
Replacement Training for Licensed Operators.
(Details 5)
M.
Liceased Operator Requalification, Completed Program Items.
(Details 6.a)
N.
Licensed Operator Requalification, Incomplete Program Items.
(Details 6.b)
O.
Abnormal Occurrence Report - A0 74-15.
(Details 7.a)
P.
Abnormal Occurrence Report - A0 74-17.
(Details 7.b)
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Q.
Loss of RC/RCS Pressure Procedure.
(Details 8)
R.
Brush Recorder Calibration-Response to Violation.
(Details 9)
S.
Previous Open Item - Report 50-289/74-14.
(Details 10.a)
T.
Previous Open Item - Report 50-289/74-24.
(Details 10.b)
U.
Previous Open Item - Report 50-289/74-29.
(Details 10.c)
V.
Control Switch Investigation.
(Details 11)
W.
Plant Tour.
(Details 12)
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DETAILS
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1.
Persons Contacted On-Site
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Metropolitan Edison Company
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Dr. T. S. Baer, Engineer-Senior
Mr. D. E. Ba"ry, Supervisor of Instrumentation
Mr. K. E. Betie, Radiation Protection Supervisor
Mr. E. E. Belmer, Mech'nical Engineer
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Mr. M. R. Buring, Health Physicist (Reading Office)
Mr. J. J. Colitz, Unit 1 Superintendent
Mr. N. E. Derks, Administrator-Nuclear and Technical Training
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Mr. J. R. Floyd, Supervisor of Operations - Unit 1
Mr. C. F. Gilbert, Supervisor of Operations - Unit 2
Mr. C. E. Hartman, Electrical Engineer
Mr. J. G. Herbein, Station Superintendent
Mr. N. S. Hernisney, Me<chanical Maintenance Supervisor
Mr. G. A. Kunder, Engineer
Mr. K. A. Lebo, Clerk-Typist
Mr. C. F. Leonard, Mechanical Maintenance Supervisor
Mr. H. M. Mitchell, Electrical Supervisor
Ms. C. A. Nixdorf, Office Supervisor-Nuclear
Mr. L. G. Noll, Control Room Operator
Mr. D. C. Orlandi, Lead Instrument and Control Engineer
Mr. W. E. Perks, Shift Foreman - Unit 2
Mr. J. F. Peters, Administrator
Mr. W. E. Potts, Supervisor-Quality Control
Mr. C. E. Randolph, Engineer Assistant
Mr. R. A. Rice, Security Specialist
Mr. J. L. eeelinger, Supervisor of Training
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Mr. D. M. Shovlin, Supervisor of Maintenance
Mr. B. G. Smith, Shift Supervisor
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Mr. M. G. Snyder, Maintenance Foreman
Mr. J. H. Thomas, Coordinator of Services
Mr. H. L. Wilson, Instrument Foreman
Mr. R. W. Zechman, Training Specialist
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Porter-Gertz Consultants, Inc.
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Mr. S. W. Porter, Jr., Consultant
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United Engineers and Constructors
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Mr. F. M. Mikolajczyk, Instrument Supervisor
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2.
General Employee Training
The inspcetor reviewed the training provided for regular employees
with respect to the requirements of 10 CFR 19, ANSI N18.1 - 1971,
and 10 CFR 50, Appendix B, Criteria II, V and XVII.
The following,
based upon discussions held with and documentation furnished by
licensee personnel, summarizes the inspector's findings.
Radiological Health and Safety Training
a.
The licensee's program requires that personnel receive approx-
imately four (4) hours of training which covers the following
items:
(1) Health protection problems associated with radiation.
(2) Methods / techniques to limit / minimize exposure.
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(3) Purpose and functions of protective devices.
(4) Dose / exposure limits.
The licensee's program did not require training with respect
te the specific requirements of 10 CFR 19.12.
10 CFR 19.12 requires,.in part, that: "All individuals working
in or frequenting any portion of a restricted area.....shall
be instructed of their responsibility to report promptly to
the licensee. any condition which may lead to or cause a
violation of Commission regulations and licenses or unnecessary
exposure to radiation or to radioactive material;....and
shall be advised as to the radiation exposure reports which
workers may request pursuant to 19.13."
In addition to lack of documented training in these items,
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licensee personnel stated that this specific training had not
been accomplished.
Failure to provide the required instruction is a violation
of the requirements of 10 CFR 19.12.
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b.
Facility Contingency Procedure Training
Documentation was available and a program was defined for this
area of training. To date, training has been conducted in
Radiation Emergency P..cedures.
Training had been scheduled
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(for October and November) to include training in the items
listed below; however, since training had not yet been com-
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pleted, it could not be reviewed at this time.
(1) Natural Disaster Procedures, including:
(a) Earthquake Procedures,
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(b) Floeding Procedures, and
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(c) Tornado Procedures.
(2)
Fire Procedures.
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(3) Personnel Injury (during other drills) .
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This item is open.
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c.
Facility Access Control and Security Training
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Employees had received some documented training in this area
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from the Security Department.
Though existing documentation
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only indicated that employees were aware of search requirements,
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discussions indicated that much more training had been given.
Documented training of a more extensive nature was available
for the last two " groups" of new employees which had received
the training.
Where documentation was lacking, the inspector
questioned selected employees to verify that indicated train-
ing had been accomplished.
The licensee discussed several
methods being considered to alleviate the lack of documentation,
lack of a delineated program, and lack of effective means of
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evaluation of the effectiveness of the training.
Since the
licensee's proposals were neither formalized nor fully imple-
mented, this item is unresolved.
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d.
Quality Assurance Training
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Operations Department personnel had received documented and
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evaluated training in this area.
General' employees have not
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yet received this training nor have the craft personnel (see
Details 3.a).
Training was scheduled but, since not yet com-
pleted, will be reinspected. This item is open.
e.
Industrial Health and Safety Training
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The licensee had documentation to indicate that Plant Safety
Meetings were held every other month.
Bimonthly meetings
of the Safety Co=mittee are held on alternate months.
While
subject matter was documented, the licensee stated that no
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method currently existed to ensure that personnel failing
to attend the bi-monthly meetings are informed of the safety
considerations discussed during the lectures. The licensee
acknowledged the inspector's concerns.
The licensee discussed
and proposed several possible solutions to the concern, but
no single method was selected at the definite approach to
be utilized. This item is unresolved pending completion of
one of the licensee's proposed solutions.
(1)
First Aid Training had been given to one hundred and
twenty (120) licensee personnel.
These persons had been
certified through satisfactory completion of the STANDARD
MULTI-MEDIA course of the American National Red Cross.
No deficiencies were identified, and the inspector had
no.further questions in this area.
(2)
Fire Fighting Training had been documented for one hundred
and three (103) licensee employees.
The training con-
sisted of five (5) one and one-half (1b) hour courses
of lec6ure and practical instructions.
No deficiencies
were identified, and the inspector had no further
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questions in this area.
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3.
Maintenance Personnel Training
The training was reviewed with respect to ANSI N18.1 - 1971,
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ANSI N45.2.6 - 1973 and 10 CFR 50, Appendix B, Criteria II, III,
V, VI and XVII. The findings summarized below are based on
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documentr. tion furnished by and discussions held with licensee
personnel.
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Quality Assurance Training
a.
Job related quality assurar.ce training had been scheduled, but
not yet given.
This item is open and will be inspected
after scheduled training has been accomplished.
b.
Procedure Review / Indoctrination
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Instructions in Tagging and Switching 2rocedures had been given
and evaluating tests administered and graded.
Persons passing
the test were listed as qualified to perform switching.
The
requirements to adhere to procedures and the methods and
reasons to change procedures as well as the training in the
use of and requirements for jumper / lifted lead control procedures
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had been given, according to the licensee, but not documented.
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This training was verified by questioning two (2) employees.
The licensee had issued to all foremen, verbal instructions
which required that a review of the precautions, limitations
and salient procedural steps of preventive and corrective
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maintenance be given prior to initiation of a maintenance
task. The licensee indicated that several possible methods
were being considered which would require and document such
training in the future. Ecwever, no distinct plan or definitive
commitment emerged from the discussions.
The licensee acknow-
ledged the desirability of requiring and documenting this
training and stated that appropriate administrative directions
would be promulgated. Until such directions are formalized
and implemented, this item is unresolved.
Job Related Health Physics Training
c.
A forty (40) hour course of instruction was documented for
maintenance personnel.
The course covered the following items.
(1)
Contacination control.
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(2)
Exposure / dose control.
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(3)
Personnel monitoring equipment.
(4) Personnel and equipment decontamination methods.
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No deficiencies were identified and the inspector had no
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further questions in this area.
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d.
On-the-Job Training
Defined and documented training programs covering classi-
fications from probationary periods through job foreman were
waintained for all I&C, Mechanical and Electrical Maintenance
workers. Job specification training and ancillary records
indicated that the following items have been accomplished.
(1) Participation in calibration, testing and equipment
acceptance programs.
(2) Demonstrated proficiency in the use of tools and equip-
ment used in the job position.
(3) Related Technical Training.
(e.g. 4 week computer main-
tenance school; pump manufacturers on-site lecture on
plant pumps.)
(4) Training in the tests and inspection that the individual
performs.
(5) Familiarization with test equipment.
(6) Training in the methods used to verify that equipment is
in proper condit.'on for measuring, inspection or testing
use.
No deficiencies were identified and the inspector had no
further questions in this area,
e.
Records
The licensee's records included:
(1) Quizzes taken to demonstrate proficiency in certain
areas;
(2) Education, experience and past performance; and,
(3) Training and retraining accomplished (when documented).
No deficiencies were identified with the records currently
being maintained.
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4.
Welder Qualification / Certification Training
The inspector reviewed the licensee's reccrds with respect to the
pertinent requirements delineated in Section IX of the ASME B&PV
Code and Criteria II, V, IX and XVII of Appendix B to 10 CFR 50.
The licensee's approach and handling of conditions of restricted
accessibility were also discussed.
The results of the inspection
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are su=marized below.
a.
Welder / Welding Procedure Certification
The licensee has no in-house document to control this area;
he uses the ASME B6PV Code directly.
Since the Code does not
address the questions of restricted accessibility and vis-
ibility, the licensee had no written guidance in that partic-
ular area. Hovever, the licensee indicated that training for
an up-coming maintenance job, requiring welding within 24" of
a floor, was currently being conducted through use of a mock-
up.
The licensee further stated, that when conditions of
limited accessibility or visibility had previously been
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encountered, mock-ups had been erected and testing given
whenever such training had been " considered necessary."
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Current documentation included the items listed below.
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(1) A record of the procedures, including the essential
variables, under which welders were examined and the
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results of the examinations.
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(2)
Each qualified welder is assigned an identification
number which is used to identify his work.
(3)
The licensee has a system whereby he reviews the work
performed by the welders and keeps records of the jobs
performed.
These records are then, according to the
licensee, periodically reviewed to determine when a welder
requires requalification.
Since the licensee's record
keeping system was not prescribed or controlled by any
administrative instrument, the inspector asked how the
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records would be maintained if the single responsible
supervisor were absent when welding was required to be
performed. The licensee responded that the forms were
self-evident and no instructions were necessary to ensure
that these forms were properly used and maintained.
To
verify the licensee's hypothesis, the inspector requested
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that another licensee employee determine which man was
qualified to perform a designated welding process.
With-
out any previous indoctrination and using only the
licensee's records, the selected employee was able to
furnish the inspector with the requested information.
The inspector had no further questions in this area.
5.
Replacement Training for Licensed Operators
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The inspectcr reviewed the training program to verify that: the
curriculum covered the examination subjects listed in 10 CFR 55.21
(10 CFR 55.22 was not included because the licensee's current program
is designed only for R0 License condidates); the practical training
,
and documentation were available to support an application in
accordance with 10 CFR 55.10(a)(6); and other aspects of the training
met the requirements set forth in ANSI N18.1 - 1971.
The following
summarizes the results of that review.
a.
Curriculum
The program is set up using bot' classroom and self study
methods to cover the following 'tems.
(1)
Principles of reactor operation.
(2)
Features of facility design.
(3) General operating characteristics.
(4)
Instruments and controls.
(5)
Standard and emergency opere-ing procedures.
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(6)
Safety and emergency systems.
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(7)
Radiation control and safety.
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Each trainee is provided with a two '2) hour period on each of
his shifts to be devoted exclusively to training according to
written instructions given to all shi't supervisors.
In
addition, the trainees are assigned t, off-shift classroom
periods of study during the nominal nine (9) month training
period.
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b.
On-the-Job Training
On-the-job training is documented on PRACTICAL EVOLUTION
SHEETS which have appropriate spaces for each item to be
verified for satisfactory completion by Shift Supervisors,
Shift Foremen and (in some cases) the Training Coerdinator.
This training includes:
(1) Manipulation of the controls during day-to-day
operations.
(2)
Participation in startups and shutdowns; and
(3)
Training at a PWR Simulator.
c.
Evaluations
During the nine (9) month course of instruction, each trainee
is scheduled to receivc:
(1)
Thirteen (13) periodic written examinations;
(2)
Nine (9) periodic oral examinations; and
(3)
One (1) final comprehensive oral and written examination
similar in scope and content to the Commission administered
examinations.
(4)
A written evaluation of the trainee's simulator partici-
pation is also submitted by the simulator operator and
retained by the licensee.
d.
Records
The review of the licensee's documentation indicated that
records were available with data to substantiate each of the
following.
(1)
Details on courses of instruction given.
(2)
Course attendance.
(3) Training received.
(4)
Records of startups, shutdowns and operating experience.
The inspector had no further questions in this area.
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6.
Licensed Operator Recuall'ication Training
The Dire :torate of Licensing stated in a letter to the licensee
dated March 21, 1974 that the Operator Requalification Program
for Three Mile Island Nuclear Generating Station as submitted in
Amendment 47 to the Final Safety Analysis Report (FSAR) for Unit 1
would be acceptable subject to incorporation or satisfaction of
the comments listed in the enclosure to the letter. Amendment 48
to the FSAR incorporated or satisfied the requirements listed in
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the enclosure to the subject letter and the program thus delineated
in the FSAR was the basis for the inspection of this area of
training.
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a.
Completed Program Items
(1) Personnel have been essigned to administer the program.
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(2) The program was tcquired to be implemented within
ninety (90) days of receipt of an operating license
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which was received on April 18, 1974.
The program was
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in effect as of July 13, 1974 which met the ninety (90)
day requirement.
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(3) Lecture instructors ar= assigned and documented.
(4) Training aids, such as SOUND ON SLIDE cartridges, were
available for use in the lecture series.
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(5) A system has been established for accomplishing and
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documenting required on-the-job training and program
required reactivity control manipulations.
(6) A system has been established and used to evaluate
program participants.
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(7) Lecture attendance, until after administration of the
first annual examination, is based upon information
furnished by the Co= mission with respect to whether a
licensed individual made above or below 807. in a given
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category on his AEC examination.
(8) Changes to systems, procedures and the facility license
are being reviewed.
In addition to the inspector's
record review in this ar a, a licensed operator was
questioned on the contents of a recently (3/17/74)
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revised procedure (EP 1202-02 STATION BLACK 0UT) to verify
a knowledge level com=ensurate with the licensee's docu-
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mentation.
No attenpt was made to evaluate the competency
of the individual to stand a watch but the inspector did
determine that the selected individual was in fact familiar
with the contents of the chosen procedure.
}
(9)
Emergency and abnormal procedures are being reviewed and
documented. This item was also verified by the questioning
of another inspector selected licensed operator with
respect to the contents of Emergency Procedure 1202-14,
LOSS OF RC FLOW /RCP TRIP.
Again, no attempt was made to
evaluate the competency of the selected individual with
respect to watch standing.
The selected individual was
familiar with the selected procedure.
.
The inspector had no further questions on the above completed
program items.
f
b.
Incomplete Pronram Items
The items listed below are not, and are not required to be,
,
comp' ate at this time.
.
(1)
e
inistration and grading o? the first annual examination,
.equired on or before July 13, 1975, was not completed.
(2)
Supplemental retraining and program participation, pre-
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dicated on the results of the annual examination, could
not be evaluated until after the first annual examination
has been given and graded.
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These items are open and will be reinspected.
7.
Abnormal Occurrence Reports
The licensee had previously reported the below listed abnormal
occurrences to RO:I on the dates indicated.
The inspector
evaluated and verified the licensee's corrective actions as
specified in those reports and the licensee's evaluations as
required by his Technical Specifications.
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a.
A0 74-15
On September 11, 1974 a Reactor Building Spray valve, BS-VIB,
failed to respond to an OPEN signal while the quarterly sur-
veillance of the Reactor Building Cooling and Isolation System
logic was being performed.
The failure was traced to a blown
fuse which was the result of an improperly installed wire
combined with a spurious ground on the 1A station battery.
This
set up, in conjunction with the valve actuation signal, a
current path to ground.
The licensee had removed the erroneous
wire, replaced the blown fuse and he had identified and cor-
rected the ground on the battery.
The licensee's review groups
had specified that all Engineered Safeguards Actuation System
Logic Cabinets would be given a detailed visual inspection of
the wiring to determine the existence of any manufacturer
4417) for the shutdown scheduled for November 2, 19
errors.
Since BS-VIB did open when two other automatic logic channels
and the manual actuation were tested and since this valve did
not affect the operation of the redundant spray pump system,
no further response to this occurrence is required.
However,
since all of the recommended actions had not yet been completed,
this item is open.
b.
A0 74-17
On September 19, 1974 the Sodium Hydroxide Tank was determined
to contain 17,677 pounds of sodium hydroxide (Na0H) in violation
of Technical Specification 3.3.1.3.b which states in part:
"The sodium hydroxide tank shall contain not less than 16 000
pounds of sodium hydroxide and not more than 17,000 pounds
,
of sodium hydroxide."
The excess NaOH was determined using a previously unused,
recently revised,
surveillance test procedure. The procedural
revisions consisted of curve and calcuation adjustments
below the ZERO level indication.necessary to reflect the previousl
Inclusion of this tank
capacity resulted in the " addition" of approximately seven
hundred (700) pounds of NaOH without any physical addition
of the chemical to the tank.
The licensee's' corrective action
was to drain NaOH from the tank until it was again with the
Technical Specifications limits.
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During the inspector's on-site review of this occurrence,
several discrepancies were discovered between the numbers
used in the analysis documented in Supplement 1 to the
licensee's FSAR and the values chosen for the Technical
Specification limits.
Examples of these inconsistencies
are listed below.
(1)
FSAR Section 5.4.1, second paragraph, line 12 indicates
that the analysis is based on loss ofilil pounds of NaOH
"
,
due to reaction of aluminum exposed to the spray solu-
tion. The same,241 pound value is designated in Table 5 ^/ C
1 as the ALUMINUM REACTION number.
However, line 18 of
paragraph 2 of section 5.5.1 used a value of 2/:1 pounds
for the aluminum reaction.
(2)
FSAR Section 5.4.1, second paragraph, line 13 indicates
that the analysis is based on a total of 21.115 pounds oXL
of NaOH in the spray solution.
The same value is used ,u
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in both line 15, paragraph 2 of section'5.5.1 and as
TOTAL AVAILABLE in Tabic 5-1.
The number 21,115 is
inconsistent with the Technical Specification values
(16,000 to 17,000 pounds) even when combined'with the
615 pounds available from injection of the contents of
the Sedium Thiosulfate Tank.
20,500 pounds of NaOH is
the specified content of the Sodium Hydroxide Tank as
shown in Table 4-1.
This value (20,500) would be con-
sistent with the 21,115 pound value when credit is taken
for the 615 pounds contained in the Sodium Thiosulfate
Tank if the unavailable volumes (due to piping config-
urations) are ignored.
,
The licensee stated that Licensing was aware of the apparent
,
discrepancies and that the NSSS supplier's new analysis (not
'
included in the FSAR Supplement) was the basis for the
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Technical Specification valuq .
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Under the current analysis the 21,116 pound value represents,
according to Table 5-1, 5,934 pounds of excess chemicals plus
a margin for storage destruction.
According to the same
table, the total NaOH consumed during six weeks of MHA ex-
posure is 15,181 pIUnds of NaOH.
The inspector verified
licensee calculz.tions which indicate that, at the nominal 20
weight percent storage concentration required by the Technical
!
Specifications, approximately 590 pounds of NaOH would be
unavailable due to Sodium Thiosulfate Tank suction
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piping configurations.
The Technical Specification minimum
of 16,000 pounds, less the calculated unavailable 590 pounds,
still exceeds (16,000 - 590 = 15,410) the required amount
(15,181) without taking into account the NaOH added from the
i
Sodium Thiosulfate Tank (615 less quantity retained in the tank).
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The inspector had no further questions at this time. This item
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may be reopened following evnluation by the Directorate of
Licensing.
8.
Loss of RC/RCS Pressure Procedure
In an attempt to determine the amount of NaOH injected following a
,
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postulated accident (see Details 7.b), the inspector also reviewed
'
Procedure 1202-6, LOSS OF RC/RCS PRESSURE.
Since the amount of
solution pumped into the containment is directly affected by the
point at which suction is taken away from the Sodium Hydroxide
,
Tank, the requirement to close the suction valves (BS-V2A and
BS-V2B) when the tank reaches " low level" (a point which is unde-
fined in either the procedure or on the level gage or on associated
equipment alarms) is a violation of both Criterion V of Appendix B
to 10 CFR 50 and Section V of the Operational Quality Assurance
Plan for the facility, in that both references require in part:
'
" Instructions, procedures, or drawings shall include appropriate
quantitative or qualitative acceptance criteria for determining that
important activities have been satisfactorily accomplished."
When the inspector identified the procedural deficiency to the
licensee, he initiated a TCN (Test Change Notice) that modified
the procedure so that step 8 A (3) now requires valve closure at
an indicated level of zero feet.
This action was completed and
verified by the inspector prior to completion of the inspection.
No further response is required.
9.
Brush Recorder Calibration-Response to Aoparent Violation
An apparent violation with respect to a UE&C instrument being used
by Met Ed was identified in the letter from RO:I to the licensee
dated September 9, 1974.
The details surrounding the use of the
instrument (Details 3.e of 50-289/74-29) indicated that the instru-
ment had not been recalled by UE&C when the calibration due date
was reached.
The licensee response (Letter to RO:I dated October 1,
1974) stated that the instrument did not require any adjustments
when it was subsequently checked for calibration.
The inspector
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verified that UE6C records for the instrument indicated that no
adjustments were required when the instrument was subsequently
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calibrated.
In addition, the inspector was shown two (2) recent
instrument recall requests for UE&C instruments to be returned for
'
calibration checks, indicating recall procedures are being followed.
The item is resolved.
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10. Previously Open Items
The .1.icensee's actions with respect to the below listed open items
was reviewed with the indicated results.
A.
Report 50-289/74-14
4
In Detail 2 of the subject report, it was noted that the appli-
!
cation of the Operational Quality Assurance Program was not
established for quality affecting ac*Lvities involving GPUSC
(General Public Utilities Service Corporation).
Amendment 49
(8-1-74) to Appendix 1A of the Three Mile Island Unit 1 FSAR,
on page 1A-50 (in the discussion of the Metropolitan Edison Co./
GPU Service Corporation Interface) identified proper program
responsibilities, controls and audits,
,
f
This item is resolved.
b.
Report 50-289/74-24
In Detail 5 of the subject report, the inspector identified
concerns with stored composite sample solutions.
During this inspection, the inspector was furnished a copy of
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Plant Chemistry Procedure 1972 - PREPARATION OF A MIXED CARRIER
SOLUTION.
I
Subsequent RO:I review of this procedure revealed that it was,
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by itself, inadequate to address all of the concerns mentioned
in Detail 5 of 50-289/74-24.
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The fact that the response was it: complete was telephonically
communicated by the inspector to che licensee (Mr. G. Miller)
,
on October 24, 1974.
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This item remains open.
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c.
Report 50-289/74-29
Detail 6.b of the subject report documented an area of concern
with the licensce's methods for controlling print revisions.
The licensee has initiated a REVISED DRAWING LOG and the admin-
instrative use of the stamp which states: "THIS DRAWING HAS
BEEN CHANGED, CHECK ADMINISTRATIVE OFFICE FILE FOR REVISION."
This item is resolved.
11.
Control Switch Investigation
The licensee was asked to review his safety related systems to
determine if any. CUTLER-HAMMER Model 10250T4023 switches were in
service.
The licensee was furnished a copy of a memo which linked
this particular control switch to a diesel failure at another
facility.
The licensee identified ten (10) switches in his safety systems,
none of which were used in the same situation referred to at the
other facility, and none of which exhibited the failure mode of
.
the switch at the other facility.
The licensee's investigation
was not completed at the time of the exit interview, and further
communication with RO:I will be forthecming, according to the
licensee, when the investigation is completed.
This item is open.
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12.
Plant Tour
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Areas of the plant covered in the inspection exhibited an on-going
i
housekeeping procedure.
Several secondary water leaks were identified
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during the tours but, in each case, the inspector was informed as
!
to the component producing the leakage and was informed that the
item was scheduled for repair during the up-coming scheduled shut-
down.
In addition, on a sampling basis, doors required to be locked
by the security plan were inspected.
In all cases, each door was
locked as required.
The inspector had no further questions in these areas.
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