ML19256D426

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Insp Rept 50-289/74-23 on 740521-23.Noncompliance Noted: Lack of Documentation of 740519-20 Reactor Coolant Sys Leakage Evaluation,Mod Maint Performed W/O Procedural Control & Inappropriate Control Rod Sys Test Procedure
ML19256D426
Person / Time
Site: Crane Constellation icon.png
Issue date: 06/12/1974
From: Davis A, Spessard R, Sternberg D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19256D423 List:
References
50-289-74-23, NUDOCS 7910180768
Download: ML19256D426 (18)


See also: IR 05000289/1974023

Text

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U. S. ATO:11C ENEnCY COM'11SS10::

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DIRECTO:L\\TE OF REGULATORY OPENsTIO::S

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REGION I

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50-289/74-23

Dochet No.:

50-289

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RO Insi.cction Report !!o.:

Licens~ce :

Metropolitan Edison. Company

License :o.:

DPR-50

- Three Mile Island-Unit 1

Priority:

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Category: B-2

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Location:

Middletown, Pennsylvania

Type of Licensec: PWR, 871 MWe (B&W)

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Type of Inspection: Routine, Announced

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Datesofkn'pection: May 21 thru May 23, 1974

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May 2,' 1974

Dates of Previous Inspection:

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Reporting Inspector:

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R. L. Spessard, iteactor inspector

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Accompanying Inspectors:

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M'.

Sternberg, Reactor Inspector

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W. A. Ruhlman , 'Reac tor Inspec tor

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Other Accompanyin;; Personnel:

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Revie.ted 11y:

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A.

B'. Davis, Senior Reactor Inspector

D2:.

Reactor Operatiens Branch

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SUMMARY OF FINDINGS

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Enforcement Action

A.

Violations

1.

Contrary to Technical Specification requirements, the licensee

was unable to produce any evidence to indicate the Reactor

Coolant System leakage had been evaluated on May 19 or 20,

1974, as required when the temperature of the Reactor Coolant

System exceeds 525 F.

(Detail 10)

2.

Contrary to Technical Specification requirements, the licensee

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performed modification maintenance on the 1B Emergency Diesel

Generator on May 17, 1974, without a procedure.

(Detail 19)

3.

Contrary to the requirements of Test Instruction 9, the licensee

conducted certain control rod system tests on May 22, 1974,

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using a Test Exception to deviate from an approved procedure

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when a Test Change Netice, routed through an appropriate

approval chain, was the appropriate and required procedure

change vehicle.

(Detail 20)

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Licensee Action on Previously Identified Enforcement Items

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The licensee had taken the corrective actions described in his letters

dated April 11 and May 6, 1974, to correct the violations identified in

Reports 50-289/74-07 Detail 7a and 50-289/74-12 Detail 2.d.l.

The

inspector verified that the licensee had accomplished the actions de-

scribed in the response letters.

RO:I has no further questions on these

items.

Unusual Occurrences

A.

Two (2) Reactor Building pressure switches tripped at greater than

f our (4.0) psig during surveillance testina.

(A0 74-2, Met Ed

letter dated May 1, 1974 to Director, DL).

(Detail 16)

B.

Diesel Generator 1B f ailed to start.

(A0 74-3, Met Ed letter not

yet received).

(Detail 3 9)

C.

Control Rod Power Supply sustained fire damage.

(A0 74-4, Met Ed

letter not yet received).

(Detail 20)

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O'ther significant Findings

A.

Current Findings

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1.

The licensee has established a program for inspecting Makeup

and Purification System orifices.

(Detail 2)

2.

The SoNum ThiosulfateDas not yet been returned to full

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operational status.

(Detail 3)

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3.

The status of the licensee's Preoperational Testing, Initial

'Startup Testing and previous commitments to RO:I were in-

spected and the current completion level / implementation

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determined.

(Detail 4 through 7)

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4.

An apparent weakness was identified in the licensee's document

control system.

(Detail 8)

5.

The inspector found two (2) control room recorders operating

without chart paper.

(Detail 9)

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6.

The licensee had not established guidance as to the practices

to be followed by employees in evaluating a reactor ecclant

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leak.

(Detail 17)

7.

The inspector identified are.as of concern with the licensee's

Reactor Coolant System Leak Rate Surveillance Procedure.

The

licensee took action to correct these concerns prior to the

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completion of the inspection.

(Detail 18)

8.

The inspector observed the personnel, procedures and techniques

used to determine RCS boron concentration.

(Detail 22)

B.

Status of Previously Reported Unresolved Items

1.

The following items are resolved:

The flanged cicsures of the fuel transfer tubes have been

a..

rep, aired and successfully leak tested.

(Detail 7b(17))

b.

Type C (Isolation Valves) local leak rate testing has

been successfully completed.

(Detail 7b(17))

2.

The f ollowing items remain unresolved:

a."

The licensee's review and evaluation of the Diesel Gene-

rator Circuitry design changes has not been completed.

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b.

No procedure has been established to correct the defi-

ciency pertaining to the licensee's program for indicat-

ing the status of out of service / calibration gauges,

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- meters and instruments.

(Detail 11)

C.

New Unresolved Items

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1.

Apparent discrepancies exist in the implementation of the

surveillance test program.

(Detail 21)

Management Interview

An exit interview was held on May 23, 1974 at the conclusion of the in-

spection with the following attendees.

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Metropolitan Edison Company (Met Ed)

Mr. J. G. Herbein, Station Superintendent

Mr. J. R. Floyd, Supervisor of Operations

Mr. W. E. Potts, Supervisor of Quality Control

Mr. J. J. Colitz, Station Engineer

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Mr. J. P. O'Hanlon, Nuclear Engineer

General Public Utilities Service Corporation (GPUSC)

Mr. G. P. Miller, Test Superintendent -

Mr. J. J. Barton, Startup and Test Manager

Mr. M. J. Stromberg, Site Auditor

Mr. G. L. Roshy, Auditor

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The following sum =arizes items discussed:

A.

Makeup and Purification System Orifices.

(Detail 2)

B.

Sodium Thiosulfate Tank Operational- Status.

(Detail 3)

C.

Thermal Discharge Monitoring Equipment.

(Detail 4)

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D.

Facility Procedures.

(Detail 5)

E.

Initial Startup Test Program.

(Detail 6)

F.

Preoperational Test Program.

(Detail 7)

G.

Document Control.

(Detail 8)

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H. l Control Room Recorders.

(Detail 9)

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Apparent Violation - Reactor Coolant System (RCS) Leak Rate Sur-

veillance.

(Detail 10)

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Instrument Status Indication. _(Detail 11)

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First Aid Training - Supervisory Personnel.

(Detail 12)

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Minor Deficiencies - Emergency Drill.

(Detail 13)

M.

Chlorine Discharge Logs.

(Detail 14)

N.

Work Authorization Approval / Routing - Additional Training.

(Detail

15)

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Followup Action - /0 74-02.

(Detai1 16)

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Reactor Coolant Leak - Sample Line.

(Detail 17)

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RCS leak Rate Surveillance Procedure.

(Detail 18)

R.

Apparent Violation - Diesel Generator Fbintenance.

(Detail 19)

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Apparent Violation - Control Rod Drive System Test Procedure

Deviation.

(Detail 20)

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Surveillance Test Procedures Review.

(Detail 21)

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Boron Concentration Determination.

(Detail 22)

In each area listed above, the licensee representatives acknowledged the

information presented by the inspectors.

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DETAILS

1.

Persons Contacted on Site - - _ - -

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Metropolitan Edison Company (Met Ed)

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Dr. T. S. Baer, Station Engineer

Mr. E. E. Bulmer, Mechanical. Engineer

Mr. J. J. Colitz, Station Engineer

Mr. N. E. Derks, Shift Foreman - Unit 2

Mr. J. R. Floyd, Supervisor of Operations - Unit 1

Mr. K. H. Frederick, Staff Chemist

Mr. C. F. Gilbert, Supervisor of Operations - Unit 2

Mr. F. H. Grice, Administrator

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Mr. R. R. Harper, Instrument Foreman'

Mr. C. E. Hartman, Electrical Engineer

Mr. J. G. Herbein, Station Superintendent

Mr. T. F. Illjes, Auxiliary Operator

.Mr. G. A. Kunder, Engineer

Mr. L. A. Laine, Quality Assurance Specialist

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Mr. G. S. Millas, Mechanical Engineer

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Mr. R. P. Miller. Test Coordinator

Mr. H. M. Mitchell, Electrical Supervisor

Mr.

J.-P. O'Hanlon, Nuclear Engineer

Mr. R. H. Porter, Shif t Supervisor

thr.. W. E. Potts, Supervisor - Quality Control

Mr. W. S. Poyck, Staff Specialist

Mr. C. E. Randolph, Engineering Assistant

Mr. R. A. Rice, Security Specialist

Mr. M. J. Ross, Shift Supervisor

Mr. D. M. Shovlin, Supervisor of Maintenance

Mr. J. R. Smith, Shift Supervisor

Mr. J. W. Smith, Sr., Utility Man First Class

Mr.

H.- G. Synder, Mair'enance Foreman

Mr. J. H. Thomas, Coo .~.nator of Services

Mr. R. P. Valez, Radiation Chemistry Technician

Mr. D. E. Weaver, Instrument Foreman

Mr. H. L. Wilson, Instrument Foreman

General Public Utilities Service Corcoration (GPUSC)

Mr. J. Barton, Startup and Test Manager

Mr. T. Faulker, Senior Test Planner

Mr. R. Heward, Project Manager

Mr. C. Miller, Test Superintendent

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Mr. M. Nelson, Technical Engineer

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Mr. G. Roshy, Quality Assurance Auditor

Mr. M. Stromberg, Site Quality Assurance Auditor

Mr. R. Toole, Assistant Test Superintendent

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2.

Makeup and Purification System Orifices

This design change was reported by the licensee pursuant to 10 CFR 50. 55 (c) .

(Met Ed letter dated April 30, 1974 and 50-289/74-18,

Design Changes, Item B).

The inspector reviewed the immediate

corrective action taken by the licensee until the future corrective

action is completed (installation of new orifices).

The licensee

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has established a program consisting of UT examination of the

recirculation orifice associated with each makeup pump (total of 3

pumps).

The inspection interval for these orifices is once every

two weeks.

This program including data evaluation is being con-

ducted by GPUSC-QA.

The inspector has no further questions on this

matter at this time.

3.

Sodium Thiosulfate Tank Operational Status *

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Based on a review of facility records, the inspector verified that

the tank level instrumentation had been calibrated on Fby 8,1972

and the tank concentration met the requirements of Technical Speci-

fi.;ation 3.3.1.3 on May 16, 1974 (e.g., 34,014 pounds of sodium

thiosulfate at 26.2 weight percent solution with a pH of 9.7).

The

inspector informed a licensee representative that since the tank

concentration was very close to the lower limit of the acceptance

band (34,000 - 36,000 pounds), it would seem prudent to add addi-

tional sodium thiosulfate to the tank to insure the tank concentra-

tion would meet the Technical Specification requirements at the

next quarterly sample.

The representative indicated that the

inspector's comment would be considered.

The inspector learned

from discussions with cognizant licensee representatives that

installation and testing of the tank heat tracing and installation

of the tank insulation had not been completed.

These items remain

outstanding, and they require completion before R0:1 will recommend

to DL that License Condition 2.c.(1) be cleared or unless DL amends

the license to impose a suitable Technical Specification limit on

tank temperature.

4.

Thermal Discharge Monitoring Equipment

Facility records indicated that this equipment was tested and'in

operation prior to heating of the Reactor Coolant System above

2000F, which occurred on May 17, 1974.

This item is closed.

(Report 50-289/74-18, Detail 13.0. (2))

  • Met Ed letter dated April 11, 1974, to Director, DRO

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5.

Facility Procedures

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Based on discussions with a cognizant licensee representative the in-

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spector determined that Operating and Surveillance Procedures which

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were revised to incorporate changes created by FSAR Amendment 47 had

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been issued with the exception of the Surveillance Procedure for per-

forming In-Service Inspection.

The representative stated this pro-

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cedure would be issued in the near future, and the inspector noted

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that the procedure would not be performed until 3 years in the future.

This item is closed.

(Report 50-289/74-18, Details 13.a. (a)(c) and

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13.a. (2) (b))

6.

Initial Startup Test Program

a.

Procedures

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The inspector observed that all of these procedures had been

final approved by the TWG.

The inspector reviewed the follow-

ing procedures and verified that previous RO:I comments had

been included in accordance with the licensee's co=mitments.

(Report 50-289/74-18, Detail 6.b. Items (3) and (4))

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(1)

SP 710/2 Controlling Precedure for Post Core Load Pre-

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critical Testing

(2) TP 710/1 Zero Power Test

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Test Results

The inspector verified by review of the completed procedures

(Official Field Copy) that the licensee had accepted the test

results for TP 330/3A, Post Core Load CRDM Functional Test.

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Included in the inspector's review (on a sampling basis) was

the licensee's disposition of identified test exceptions and

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deficiencies and comparison of test data with acceptance

criteria. The inspector also observed that problems identi-

fled during hot functional testing had been corrected and

the CRDM's satisfactorily retested.

This item is closed.

(Report 50-289/74-08, Detail 6 Item e.).

Data also included

a satisfactory retest on CRD No. 29 which could not be moved

from its fully inserted position following cc=pletion of

cold /no flow CRD Trip Tests.

This problem which was reported

by the 1.'aensee by telephone to RO:I on May 15, 1974, was

corrected by venting the CRDM.

Additionally, all CRDM's were

vented.

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7.

Preoperational Test Program

The inspector reviewed TWG Meeting minutes for the period April

25 - May 21, 1974 (Meetings 103-109), completed test results

(Official Field Copy), and the status of the prerequisite list for

initial criticality.

Additionslly, the licensee's plans relative

to completion of the test program prior to initial criticality were

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reviewed.

The following information was obtained:

a.

Preoperational Testing Status

Tests Completed and 'ccepted

78%

Tests Partially Completed and Accepted

11%

Tests Completed and Under Review

7%

Tests Not Completed

4%

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The licensee does not plan to complete the tests listed below

prior to initial criticality.

Partial test completion and

licensee acceptance of partial test data are indicated where

appropriate.

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(1)

F1104/23 - Cycle Makeup Demineralizers Functional Test

(2)

F1104/6 - Spent Fuel Cooling Functional Verification

(3)

SP 102.6 - Fire Protectior. System Checkout (Partially

Completed)

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(4)

SP 254.33 - Turbine Generator Initial Operation (Partially

Completed and Accepted)

(5) TP 350/2 - Computoc 0 osm- - Field Verification (Sof tware)

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(PartiallyCompletedandpgcepted)

(6)

TP 350/10 - Computer Points Verification (Partially

Completed)

(7). TP 120/1 - Iuel Handling System Operational and Functional

Test (Partially Completed and Accepted)

(8)

TP 120/2 - Dry Fuel Handling Test (Partially Completed

and Accepted)

(9) TP 120/3 - Fuel Handling System Integrated Functional

Test (Partially Completed and Accepted)

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(10) TP 360/1A - Process Radiation Monitor Calibration and

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Functional Test - Portable Atmospheric (Partially Com-

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pleted and Accepted)

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(11) TP 230/8 - Solid daste Disposal System Test (Partially

Completed and Accepted)

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(12) Tp'230/7 - FWehanicif Draf t Cooling Tower Functional Test

The inspector informed cognizant licensee representatives that

their plans relative to not completing the preoperational test-

ing program as described in the FSAR (Section 13.1.3.2) would

constitute a change pursuant to 10 CFR 50.59(a), and therefore,

the requirements of 10 CFR 50.59 and the applicable require-

ments of the Technical Specifications (Section 6) would have

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to be cet prior to initial criticality.

The representatives

acknowledged this information.

b.

Test Results

The procedures listed below had been completed and accepted by

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the licensee unless otherwise indicated.

Included in the

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inspector's review (on a sampling basis) was the licensee's

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disposition of identified test exceptions and deficiencies and

comparison of test data with acceptance criteria.

The inspector

had no further questions relative to tha licensee's acceptance

of these results unless otherwise indicated.

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(1)

SP 267/5 - Flow Balance for FCR 218 (Hot Drain Coolers)

(2)

F1104/14E - Reactor Building Industrial Cooler System

Functional Verific:tf er.

(3) TP 302/2B - In-core vecector Pre-Installation Electrical

Test

(4)

TP 160/3 - Reactor Building Purge System Functional Test

(5)

SP 201.19 - Reactor Coolant Pump Vibration Test

(6)

TP 200/1 - Reactor Internals Vent Valve Inspection Test

(7)

F1104/29E - LWDS Functional Verification - Bleed and Feed

Processes

(8)

TP 310/4 - E.S. Annunciator and Alarm Test

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(9)

F1106/17 - Turbine High Pressure Fluid System Functional

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Verification

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(10) TP 266/4 - Nuclear Service River Water Functional Test

(11) SP 166.2 - Plant Test Panel Pre-Op Alignment

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(12) TP 600/21 - Integrated E.S. Test

(13) F1104/16 - Penetration Ccoling System Functional Test

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'(14) TP 600/29 - Reactor Coolant System Thermal Expansion

Functional Test

(15) TP 153/3 - Fluid Block System Functional Verification

.

According to the FSAR (Section 5.3.5.2), the anticipated

maximum leakage rate frem the groups of lines fluid blocked

by FB-T-1A and FB-T-1B is 0.0024 and 0.003 gpm respectively.

However, the test results disclosed the leakage rate from

both groups of lines fluid blocked by these tanks was

0.0027 gpm, thus indicating leakage in excess of the accep-

tance criterion for the group of lines fluid blocked by

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FB-T-1A.

This matter was reviewed by GAI and was deter-

mined to be acceptable on the basis of a recalculated maxi-

mum leakage rate from these lines for actual system condi-

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tions. The FSAR is to be revised to reflect the as built

maximum leakage rate criteria,

e.g., 0.00354 and 0.00347

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gpm vice 0.0024 and 0.0027 gpm.

It remains open pending

FSAR amendment.

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(16) TP 120/3 - Fuel Handling System Integrated Functional Test

This test was partially completed using a dum=y fuel

assembly prior to fuel load and the results were accepted

by the licensee.

The open item in this test involves the

ccatrol rod handling mechanism which has experienced limit

switch problems.

The licensee plans to cr rect this pro-

blem prior to refueling operations.

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(17) TP 151/1 - Reactor Building Isolation Valve Leak Tests

This test was completed and the test results were in the

licensee's review circuit. The flanged closures of the

fuel transfer tubes were repaired and data indicated

acceptabic leakage rates.

This item is resolved.

(Reports

50-289/74-18, Detail 3.a. (9)(a) and 50-289/ 74-12, Detail

2.d.(3)).

Data indicated that total Type C (Isolction

Valves) leakage corrected to Pa (55 psig) was 7,522.9

cc/ min as compared to the acceptance criterion of 7,865

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cc/ min (.2 La).

This item is resolved.

(Reports 50-

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289/74-18, Detail 3.a.(10) and 50-289/74-12, Detail 6)

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The inspector observed that the above tests had been conducted

and accepted in accordance with the licensee's commitments to

RO:I.

(Met Ed letter dated April 19, 1974 to the Director,

DRO, RO:I and Report 50-289/74-18, Details 2 and 3)

.

8.

Document Control

The FSAR (Appendix 1A) describe the lic.nsee's Operating Quality

Assurance Plan and Section VI of Appendix 1A describes Document

Control requirements. Administrative Procedure No. 1001 had been

approved and was being implemented in accordance with referenced

requirements. As a result of two separate occurrences observed by

the inspectors during this RO inspection, it appears that the

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licensee's system does not include a'dequate controls to insure that

the latest approved drawing revisions are promptly distributed in

accordance with the Unit 1 Drawing and Micro-film aperature card

distribution list.

Examples illustrating

is weakness are as

follows:

a.

Emergency Diesel Generator

During discussions with a Met Ed Electrical Engineer relative

to recent design changes made to the Diesel Generator start

circuitry, the inspector observed that the drawing being used

by the engineer (No. 11865841, Rev. 11) did not reflect these

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design changes.

This drawing had been revised (Revisions 12

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and 13) on April 4,1974, and a copy of the revised drawing,

which had been provided to RO:I during a previous RO inspec-

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tion (completed April 19, 1974), was being used by the in-

spector to conduct this review.

b.

Main Steam Line Penetration

A design change to one of the four main steam line penetra-

tions, as described in Met Ed's letter dated April 5, 1974 to

the Deputy Director for Reactor Projects, DL, was completed in

accordance with an approved GPU Work Authorization on Mty 8,

1974. During discussions with cognizant licensee representa-

tives, the inspector was informed that Met Ed personnel had

restored this enetration to its original condition because it

was observed ta be different frem the other penetrations as

described in facility drawings.

The inspector reviewed the

approved Met Ed Work Request No. 000062 used-to perform this

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work and observed that the Work Request had been initiated,

approved, and completed in accordance with Administrative

Procedure No. 1016. The work was completed on May 15, 1974.

This

condition was discovered due to an indication of excessive

flow (indicative of a leak) in the penetration pressurization

system which was the basis for the design change.

This marter was discussed with cognizant licensee representatives,

and it is considered an open item.

9.

Control Room Recorders

The inspector observed two (2) recorders operating without paper

on the Heating and Ventilation Control Panel in the control room.

Specifically, recorder No. 54, Fuel lJandling Building Exhaust Flow

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and recorder no. 56, Auxiliary and Fuel Handling Building Total

Exhaust Flow.

When the inspector observed these recorders, they

had both been out of paper for appro::imately ten (10) hours accord-

ing to the time stamp on the chart paper.

When notified of the

condition, the Shif t Supervisor immediately caused the correct chart

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paper to be installed on the recorders.

The Supervisor of Operations

stated th. t all operations personnel would again be briefed on the

importance of properly maintaining all control room recorders.

The

inspector had no further questions in this area.

10.

Reactor Coolant System (RCS) Leak Rate Surveillance

,

A' review of the logbook in the control room indicated that the reactor

coolant system was above 525 F from approximately 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br /> on May

19, 1974 thru May 23, 1974 when the inspection ended.

The inspector

requested the copies of the data sheets from Surveillance Procedure

1303-1.1 (Reactor Coolant Syrtem Leak Rate) for the period from May 19

through May.22, 1974.

The licensee representatives were unable to

locate any data sheets for May 19 and 20, 1974.

In addition, there was,

according to the Supervisor of Operations, no evidence to indicate that

required leak rate determination / evaluation had been perfor=ed

prior to May 21, 1974.

The licensee representative was informed

that the lack of Reactor Coolant System Leak Rate determination / evaluation

was in violation of the requirement of Technical Specifications

Table 4.2-1, Item 7 which states that daily, when reactor coolant

system temperature is greater than 525 F, RCS leak rate must be

evaluated. The representative acknowledged the information

11.

Instrument Status Indication

A deficiency was identified (Report 50-289/74-21, Detail 3) with the

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licensee's program for indicating the operating status of equipment,

especially out of service / calibration meters and instrumentation.

The licensee representatives stated that a system requiring the use

of special tags had been devised and that tags had been ordered.

The licensee representative further stated that the procedure stating

how/when these new tags were to be used had not yet been written or

approved._.S_ince the licensee _had_not yet completed or implemented a

.

system to alleviate the deficiency noted,.this item remains unresolved.

12.

First Aid Training-Supervisory Personnel

The sole remaining deficiency with respect to emergency training was

identified (Report 50-289/74-10, Detail 7) at the time of the Emer-

gency Training Exercise as the lack of intensive first aid training

for various supervisory licensee personnel. Records furnished by the

.

licensee during this inspection indicated that these personnel had

received the required training during a forty (40) hour course of

first aid instruction given during the period of March 11, through

15, 1974.

This item is now resolved.

13. Minor Deficiencies-Emergency Drill

,,

The minor deficiencies identified by both the RO:I inspector and the

licensee (Report 50-289/74-10, Detail 8) during the conduct of the

Emergency Training Exercise were not considered as serious or out-

standing items with respect to emergency planning.

However, the

inspector did discuss the action taken on all of these items with

licensee representatives during this inspection.

The licensee had

taken action on each item to ensure that the noted deficiency was cor-

rected and had taken steps to prevent recurrence. RO:I has no further

questions on these items.

14.

Chlorine Discharge Logs

In a letter dated March 29, 1974, RO:I identified a violation with

respect to chlorine monitoring associated with the chlorination

systems.

(Report 50-289/74-07, Detail 7a).

In the Metropoligan

Edison response to RC:I dated April 11, 1974, steps were outlined to

correct the deficiency. The inspector verified that the chlorine

usage logs referenced in the response were in use and reviewed weekly

by the chemistry foreman.

In addition, the training of persennel res-

ponsible for maintaining the log was verified in discussions with the

cognizant supervisor.

R0:I has no further questions in this area at

this time.

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15. Work Authbrication Approval / Routing - Additional Training

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In a letter dated April 16, 1974, RO:I identified a procedural vio-

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lation with respect to work performed without a completed and approved

work authorization.

(Report 50-289/74-12, Detail 2.d.1).

The cor-

rective action specified in the-licensee's response dated May 6, 1974

consisted of additional training for all supervisors functionally res-

ponsible for station operation or maintenance.

The training, a man-

datory three-(3) hour classroom session on the administrative proce-

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dures covering Work Authorizations / Work Requests together with approved

work implementation procedures for all work on Quality Control related

systems, was given as stated in the letter.

The inspector verified the

licensee's implementation of the corrective action by questioning a ran-

domly selected supervisor about the contents, requirements and duration

of th'e lecture.

R0:I has no further questions in this area at this

time.

,

16.

Followuo Action-A0 74-02

The licensee stated in a letter dated May 1,1974, that the followup

action to correct the out of specification settings on the Reactor

Building High Pressure reactor trip pressure switches consisted of

__

making the setpoint for the switches 3.75 psig instead of the old set-

point of 4 psig. This action was taken based upon a review of the

technical manuals for the switches by on-site engineering personnel

who co,ncluded that the potential setpoint error was +0.135 psig.

The

inspector was shown documentation which indicated that the new setpoint

(S.75 psig) had bean set on each of the four (4) pressure switches as

indicated in the licensee's letter.

R0:I has no further questions in

this area at this time.

17.

Reactor Coolant leak - Samole Line

The inspector observed water dripping from the area of a fitting near

a valve in the sample line connected to the Pressurizer.

A licensee

representative was informed of the leakage.

This representative

evaluated the leakage and determined that the source of the water was

the reactor coolant system; shutoff valves upstream would isolate the

leak if closed; both samples and direct reading methods indicated

that thert was no detectable radiation.

The area was roped-off and

posted as possibly contaminated and the shutoff valves upstream of the

leak were closed. A formal evaluation was conducted the next morning

by the Plant Operations Review Committee (PORC) .

The PORC concurr2d

with the initial evaluation but ordered a complete survey of al] valves

and lines in the sample sink area as an additional precaution.

The

survey ordered did discover some additional leakage and potential leak-

age probl. css and a work request was issued to fix all identified prob-

lems.

However, during discussions with cognizant licensee represenca-

tives in the course of following the actions taken above, the inspector

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determined that the licensee did not have any definitive instructions

which covered the actions to be taken with regards to: what manage-

. ment level is required to make an evaluation of leakage; what level of

evaluation is required with respect to causes, severity, potential

hazards, unreviewed safety questions, generic implication and other

salient points of interest.

The inspector stated that R0:I had no

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further questions with respect to the actions taken on the particular

leak mentioned above; however, the licensee's lack of instructions

covering this area remains an open item.

The licensee representatives

acknowledged the inspector's statements and stated that the areas of

concern mentioned by the inspector would be evaluated.

18.

RCS Leak Rate Surveillance Procedure

In his review of the RCS Leak Rate S.urveillance Procedure (1303-1.1)

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the inspector expressed concerns in the following areas:

a.

The procedure used the approximate values for cubic feet per pound

mass per degree Fahrenheit and the values were only identified for two

(2) distinct temperatures.

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b.

The procedure did net prohibit makeup to the system during the test

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nor did it account for any makeup =ade during the test.

Before' leaving the site, the licensee had approved and issued changes to

the procedure which eliminated both of the inspector's concerns.

The

inspector had no further questions in this area.

19. Diesel Generator Maintenance

Modification maintenance to the 13 Emergency Diesel Generator was per-

formed on May 17, 1974 without a procedure.

This maintenance consisted

of installing a larger diameter pressure sensing line for a low speed

oil pressure switch and re-installation of this switch following a test

in a temporary location. During this sensing line installation, 3 other

lube oil pressure switches were left disconnected.

A post maintenance

start of the diesel was attempted and the diesel shutdown at 810 rpm

due to the disconntected pressure switches.

Th _ s maintenance action is a violation of Technical Specification Section 6.2, which requires all =aintenance which affect nuclear safety

be accomplished using detailed procedurec.

The licensee stated he generated a procedure to correct this action

and that he will use it during the installation of the modification

of the 1A Emergency Diesel Generator.

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20.

Control Rod Drive System Test Procedure Deviation

While performing rod drop response time tests on May 22, 1974 with

the primary system in a hot, no-flow condition, a test procedure

change was proposed.

This change was intended to shorten the

duration of the test. The intent of the change was to pull two rods

at the same time, specifically a Group 2 rod with Group 5.

A Test

Exception was taken and the Group 2 rod was re-patched into Group 5

and a Group 5 rod was left unpatched.

During the re-patching the

motor power leads were transferred into Group 5, but the logic and

control patch was not moved.

This resulted in a fire and damage to

the control circuitry when the re-patched rod was placed on the

Auxiliary Rod Bus.

The use of a Test Exception to change the procedure was a violation of

.

Tcst Instruction 9, Conduct of Test,' paragraph 3.3.2.6 which states in

part,". ..During the performance of tests certain conditions may occur

th'at prevent the test from being performed as written.

Changes to the

test procedure are made by making an exception to it or by initiating a

Test Change Notice (TCN).

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A TCN is required if the. proposed change affects the procedure's scope or

intent. A Test Exception Change does not change the scope or intcnt

of the procedure. . ."

.

Since the scope of the procedure was changed by the re-patching, a TCN

which would have required detailed procedures should have been used in

this situation.

21.

Surveillance Test Procedure Review

The inspector reviewed surveillance procedures completed la the areas of

the Reactor Protection and Engineered Safeguards systems.

The data

reviewed had completed the licensee's review process, described in Admin-

istrative Procedure No. 1010 and were selected in a random manner by

the inspector.

Several general areas of concern were identified including unauthorized

changes to procedures, failure to follow the procedure, and incorrect

handling of test deficiencies.

Several typical examples are included

below to illustrate these com=erts.

a.

Failure to follow procedures:

1.

S.P. 1302-5.1,5.5 performed on February 25, 1974 and April

1, 1974 had data sheets which were not signed by the foreman

as required (Data sheets on page 65 and 4 and 5 respectively)

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S.P. 1303-11.11 performed on March 14,197equired that the

specific gravities of individual battery cells be recorded.

No such data

3 entered on Data Sheet 3.

b.

Unauthorized changes to Procedures

1.

S.P. 1302-5.1,5.5 performed on April 1, 1974 had the re-

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quired values to be obtained changed in part 6.1 with no

explanation.

.

2.

S.P. 1302-5.6 performed on March 4, 1974 had the required

values to be obtained changed on Data Sheets 3,5,6 and 7

with no explanation.

c.

Incorrect Handling of Test Defi,ciencies

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1.

S.P. 1303-5.1, 5.3, 5.8 performed on February 25, 1974 and

April 2, 1974 on pages 33.0, 34, 35a and 35b indicated that

certain circuit breakers were " Red Tagged" rather,than in-

dicating if they were in the required position for the test.

No Test Exception or Deficiency was noted.

These deficiencies occurred during surveillance tests performed prior to

the issuance of the Operating License on April 19, 1974.

Cognizant

licensde representatives were informed that if these deficiencies re-

mained uncorrected and the tests were used as a part of the bases for

'

allowing achievement of initial criticality, then this would be in

violation of the Technical Specifications.

The representatives tek-

nowledged the inspector's statement. This is considered an unresolved

item.

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22.

Boron Concentration Determination

As part of the Initial Criticality pre-requisite review, the in-

spector observed a licensee's representative determine the Boron

concentration of the primary coolant.

It was observed that this was

done in accordance with the procedure, in a timely fashion and that

the person performing it was knowledgeable of the procedure.

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