ML19261E874

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IE Insp Rept 50-289/77-05 & 50-320/77-09 on 770222-25. Noncompliance Noted:Failure to Take Corrective Action Per Commitments to NRC Per 10CFR50 & Operational Quality QA Plan & Failure to Document & Correct QA Conditions
ML19261E874
Person / Time
Site: Crane  
Issue date: 03/23/1977
From: Davis A, Durr J, Fasano A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19261E857 List:
References
50-289-77-05, 50-289-77-5, 50-320-77-09, 50-320-77-9, NUDOCS 7910170919
Download: ML19261E874 (47)


See also: IR 05000289/1977005

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(1 J75) (Rev)

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U. S. NUCLEAR REGULATORY CC10iISSION

OFFICE OF INSPECTION AND E'iFORCDfENT

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REGION I

50-289

IE Insp. ction Report No:

50-289/77-05 and 50-320/77-09

Docket No:

50-320

DPR-50

Licensee:

Metropolitan Edison Company

License No:

CPPR-66

P. O. Box 542

Priority:

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C

Readino, Pennsylvania 19603

Category:

B-1

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Safeguards

Location:

Middletown, Pennsvivania (Three Mile Island)

Unit 1:

PWR 2535 MWt (B&W)

Type of Licensee:

Unit 2:

PWR 2772 MWt (B&W)

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Ty" of Inspec tion:

Routine, Announced

a

February 22-25, 1977

Da ) of Inspection: _

Unit 1

Dates of Previous Inspectio1:

February 17-18,1977- and 2

Reporting Inspector:

b . / /k,s

3/23/77

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ArR. Fasano, Reactor Inspector

DAIE

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3/E3/77

Acconpanying Ins ectors:

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3/23 /7?

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J/T. Smiff, Reactor [nsp

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Other Acconpanying PersonneI:

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DATE

Reviewed By: Q1Mhm

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n, e-

A. B. Davis, Chief, Reactor Projects Section No.1,

DATE

Reactor Operations and Nuclear Support Branch

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SUMMARY OF FINDINGS

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Enforcement Action

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Infr actions

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77-05-01. Failure to take corrective action in accordance with commit-

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ments to the NRC contrary to 10 CFR 50, Appendix B, Criterion XVI and

the accepted Operational Qu .lity Assurance Plan (FSAR Section 1A)

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Section 6.7.

(Details S.a and 8.b)

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Unit 2

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77-09-01, Failure to establish / document measures and failure to correct

conditions adverse to quality as soon as practicable contrary to 10 CFR 50, Appendix B, Criterion XVI and the accepted Operational Quality Assur-

ance Plan (FSAR Section 17.3) Section 17.3.2.

(Detail 18.a)

(])

Licensee Action on Previously Identified Enforcement Items (Unit 1)

)

Corrective actions taken in response to NRC:I Inspection Reports

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50-289/76-11 and 50-289/76-19 had not been completed in accordance

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with the licensee's commitments.

(Details 8.a and 8.b)

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Corrective action taken in response to NRC:I Inspection Report

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50-289/76-25 has been completed.

This item, 76-25-1, is resolved.

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(Detail 8.c)

Desion Chances

None rep';rted.

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Unusual Occurrences

None reported.

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Other Significant Findings

A.

Current Findings

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Acceptable Areas

(These are items which were reviewed on a sampling basis and

findings did not involve any Items of Noncompliance, Deviations,

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or Unresolved Items except where noted.)

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Unit 1

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Nonroutine Event Reports.

(Detail 3)

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Seismic Qualification of Steam Generator Level and Pressure

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Indications.

(Detail 4)

IE Bulletin / Circular Followup.

(Detail 5)

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Safety Limits, Limiting Safety ' stem Settings, and

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Limiting Conditions for Operation.

(Detail 6)

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Plant Operations.

(Detail 7)

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Corrective Action for Previously Identified Enforcement

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Items.

(Detail 8)

Previously Reported Unresolved /Other Items.

(Detail 9)

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Unit 2

Receipt, Storage, and Handling.

(Detail 11)

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Tests and Experiments.

(Detail 12)

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Design Changes.

(Detail 13)

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Surveillance Testing and Calibration.

(Detail 15)

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Preoperational Test Records.

(Detail 17)

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Startup and Test quality Assurance Program.

(Detail

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18.b)

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2.

Varesolved Items

Unit 1

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77-05-02, DH-V1 Supplemental Engineering Report and Val se

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Repair Schedule.

(Detail 3.c(1))

77-05-03, Replacement of OPLS Switches and Revision of

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Procedure 1301-8.2.

(Detail 3.c(3))

77-05-04, Special Test Procedure for Testing the Reactor

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Building Spray System.

(Detail 5.b)

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77

3-05, Complette

of Revision Documentation of Limitorque

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Ad. 2stment Procec'

(Detail 5.d)

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77-05-06, Controls over Safety Related Censumable Material .

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(Detail 7.b(6))

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77-05-07, Revision of AP 1001 to Establish a Program for

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Review of Safety Related Facility Procedures.

(Detail

8.a.)

See 77-05-01.

77-05-08, Completion of I&C and Electrical Maintenance

G)

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Personnel Training on AP 1013.

(Detail 8.b.)

See 77-05-

01.

77-05-09, Review of NRC:I Inspection 50- 39/76-08 Item of

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Noncompliance by GORB.

(Detail 9.c)

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77-05-10, Record Storage Inadequacies.

(Detail J.e)

77-05-11, Hausekeeping Procedure.

(Detail 9.k)

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77-05-12, Revise Prot eduro AP 1016 to Specify How Modifica-

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tions Are sent to Training.

(Detail 9.p)

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77-05-13, Determine Adequacy of Response to Circular 76-

06.

(Detail 5.b)

Unit 2

77-09-02, Requirement by QA Procedure to addr_ss minimum

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documentation criteria for Certificates of Conformance.

(Detail 10.a)

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77-09-03, Issue Station Administrative Procedure 1020 to

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cover Control of Housekeeping and the Establishment of

Housekeeping Zones.

(Detail 14)

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77-09-04, Consumable Items to be Listed on the New QA

Systems List for TMI-2.

(Detail 16)

3.

Inspector Followup Items

Unit 1

77-05-12, Status of Procedure Change Request Completions.

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(Detail 9.r)

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77-05-13, Log Sheet Notation Reference to TS.

(Detail

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7.a(1))

77-05-14, Protective Clothing Distribution Point Problem.

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(Detail 7.b(2))

Unit 2

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77-09-05, Unit 1 Extraction. Steam for Unit 2, Procedures.

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(Detail 19)

B.

Status of Previously Identified Unresolved Items

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Unit 1

1.

The following items have been resolved:

a.

Item 76-01 (Detail 13.b.(8)) and 76-17 (Detail II.11),

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GORB Review of TS and License Violations Delineated in

NRC:I Inspection Reports for Calendar Year 1975.

(Detail

9.a)

b.

Item 76-10 (Detail 3.b.(1)(b)), Radiation Chemistry Tech-

nician Training on Precedure HP 1631.

(Detail 9.b)

c.

Item 76-15 (Detail 21), Reactor Building Purge System.

(Detail 9.d)

d.

Item 75-14 (Detail 12.b), Record Storage Inadequacies. .

(Detail 9.e)

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e.

Item 76-24-2, FSAR Change for RCP Monitor Delay Time.

(Detail 9.f)

f.

Item 76-24-3, Additional Evaluation of ER 76-18/1T.

(Detail 9.g)

g.

Item 76-24-4, Repair of Valve MU-V28.

(Detail 9.h)

h.

Item 76-24-5, Long Term Corrective Action for ER 76-28/4T

and 76-35/1T.

(Detail 9.i)

1.

Item 76-24-10, GORB Review of Reportable Occurrences.

(Detail 9.j)

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Item 76-24-12, Revision of Procedure GP 4015 to Include

Crite:ia on Due Date Fxtensions.

(Detail 9.1)

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Item 76-24-13, Revise Procedure GP 4015 to Include Criteria

on Closecut.

(Detail 9.m)

1.

Item 76-24-14, Verify that Audit Report 75-25 is available

at Site QC Files.

(Detail 9.n)

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Item 76-24-15, Revise GP 4407 to Designate Duplicate QC

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Record Storage Requirements.

(Detail 9.o)

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Item 76-24-17, Verify Completion of Corrective Action on

NCR TMI 76-439.

(Detail 9.q)

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2.

The following items remain unresolved:

Unit 1

a.

Item 76-10 (Detail 8.b.(4)) and 76-17 (Detail II.10.d),

GORB Review of License Violations Delineated in NRC:I

Inspection Report 50-289/76-08.

(Detail 9.c)

This item is redesignated as Item 77-05-09.

b.

Item 76-24-11, Housekeeping Procedure.

(Detail 9.k)

This item is redesignated as Item 77-05-11.

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Item 76-24-16, Revise Procedure AP 1016 to Specify How

Modifications are Sent to Training.

(Detail 9.p)

This item is redesignated as Item 77-05-12.

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Management Interviews

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Unit 1

Entrance Interview

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An entrance interview was conducted at the site, Unit 1, on February 22,

1977, with the Unit 1 Superintendent and the Unit 1 Supervisor of Opera-

tions. The inspector described the scope, estimated duration, personnel

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to be contacted, and records to be reviewed as part of the inspection

on Unit 1.

The licensee was informed that a Unit 2 QA oriented inspection

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would be conducted at the Met Ed Corporate Headquarters.

Unit 2

Entrance Interview

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An entrance interview was conducted at Met Ed Corporate Headquarters on

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February 23, 1977, with the Supervisor of Quality Assurance and the Section

Head of Licensing.

During the meeting the inspector described the scope,

estimated duration, personnel to be contacted, and records to be reviewed

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as part of the inspection on Unit 2.

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Exit Interviews

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Three exit interviews were conducted.

A.

The first exit was held at the Unit 1 plant, February 2E,1977.

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The items discussed are described in the details of this report

designated as affecting Unit 1.

The licensee attendees are desig-

nated with asterisks by their name as listed in Detail 1, Persons

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Contacted.

B.

The second exit was held at the Unit 2 GPU trailer complex onsite,

February 25, 1977.

The items discussed are described in Details

17,18, a nd 19.

The licensee attendees are designated in Detail 1,

Persons Contacted,

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C.

The third exit was held at the Met Ed Corporate Headquarters, Read-

ing, Pennsylvania on February 25, 1977, at the conclusion of the

inspecticn with the following licensee attendees:

Metropclitan Edistn Company (Met Ed)

Mr. L. L. Lawyer, Manager, Operational Quality Assurance

Mr. W. E. Potts, Section Head, Licensing

Mr. R. N. Prabhaker, Supervisor, Quality Assurance

The scope and objectives of the inspection were discussed and the

inspection findings were presented as detailed in this report,

specifically the Items of Noncompliance and those items related

to Unit 2 Quality Assurance Prcoram.

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DETAILS

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Persons Contacted

General Public Utilities Service Corporation (GPUSC)

    • Mr. R. F. Fenti, Quality Assurance Auditor
    • Mr. P. A. Levine, Quality Assurance Auditor
    • Mr. M. A. Nelson, Technical Engineer
    • Mr. M. J. Stromberg, Chief Quality Assurance Auditor
    • Mr. R. J. Toole, Test Superintendent

Mr. J. E. Wright, Site Quality Assurance Manager

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United Engineers and Constructors, Incorporated (UE&C)

Mr. S. Bailey, Mechanical Engineer

Mr. R. Barley, Lead Mechanical Engineer

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Mr. B. A. Bozarth, Quality Control Phase II Engineer

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Mr. R. T. Carlson, Test Engineer

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Mr. S. Kakarla, Lead Engineer

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    • Mr. D. C. Lambert, Field Supervisor, Quality Control

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Mr. D. R. Rayne, tead Mechanical En9 neer

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Metropolitan Edison Company (Met Ed)

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Mr. M. Beers, Shift Supervisor

    • Mr. R. Bensel, Electrical Engineer

Mr. S. H. Bonneville, Administrative Assistant, Quality Control

Mr. T. Book, Shift Foreman

Ms. R. Brown, Technic?.1 Analyst, Generation Engineering

Mr. J. Chwastyk, Shift Supervisor

  • Mr. J, J. Colitz, Unit I Superintendent
      • Mr. W. W. Cotter, Supervisor, Quality Control

Mr. E. Crawford, Electrical Maintenance Foreman

Mr. T. Crouse, Control Room Operator

Mr. B. Deiter, Control Room Operator

Mr. D. Dubiel, Acting Supervisor, Radiation Protection and Chemistry

Mr. J. Fritzen, Senior Engineer

  • Present at Unit 1 exit interview
    • Present at Unit 2 exit interview
      • Present at both Unit 1 and 2 exit interviews

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Mr. J. Hall, Inservice Inspection Engineer

n '. C. E. Hartman, Lead Electrical Engineer

Mr. E. V. Kellogg, Technical Analyst III

  • Mr. G. A. Kunder, Unit I Supervisor of Operations

Mr. R. G. Kobstein, QA Engineer II

Mr. L. L. Lawyer, Manager, Quality Assurance

l%. G. A. Loignon, Jr., Engineer I

    • Mr. T. Mackey, Engineer II, Nuclear

Mr. J. Masters, Auxiliary Operator

    • Mr. G. P. Miller, Unit 2 Superintendent (by phone only)

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Mr. H. Mitchel, Electrical Aaintenance Supervisor

  • Mr. J. P. O'Hanlon, Unit Superintendent, Technical Support

Mr. V. Orlandi, IaC Lead Engineer

Mr. L. Noll, Shift Foreman

Mr. D. Pilsitz, Shift Foreman

Mr. W. E. Potts, Supervisor of Licensing

Mr. R. N. Prabhakar, Supervisor, Quality Assurance

Mr. W. J. Sawyer, Engineer-Senior I, Nuclear

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  • Mr. M. A. Shatto, Engineer Associate III

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Mr. C. W. Smyth, Licensing Engineer

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2.

purpose and Scope of the Inweetion

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This report addresses two inspections.

Inspection 77-05, Unit 1,

was an announced inspection directed toward the review of plant

cperation activities and a review of the licensee's compliance to

s- fety limits, limiting systems settings, and limiting conditions

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for operations. The Unit 1 inspection also covered the followup

of previously identified unresolved items, items of noncompliance,

Inspection and Enforcement Bulletins, Circulars, and Licensee

event reports.

Inspection 77-09, Unit 2, was an announced inspection directed

toward the continued review of the quality assurance program for

station operations.

This inspection is based on 10 CFR 50, Appendix B Criteria, Section 17.2 of the FSAR, Quality Assurance Program for

Station Operations, and the implementing procedures.

The procedures

that implement FSAR Section 17.2 were reviewed to determine that the

procedures reflect compliance with regulatory requirements and the

licensee's commitments.

  • Present at Unit 1 exit interview

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    • Present at Unit 2 exit interview

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3.

Nonroutine Event Reports, Unit 1

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a.

Selected Reportable Occurrences were reviewed to verify that:

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The cause was identified and that details were clearly

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reported to the NRC and facility management;

Corrective action described in the licensae's report was

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taken to prevent recurrence;

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Each event was reviewed and evaluated as required by the

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Technical Specifications; and

Safety limits, limiting safety system settings, and limit-

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ing conditions for operation were not exceeded.

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This review included discussions with members of the plant

staff, inspection of PORC meeting minutes, internal site

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memoranda, physical observation of affected equipment, work

requests, and surveillance procedures.

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b.

The Rept. table Occurrences reviewed were:

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(1)

ER 76-40/3L, Abnormal Degradation of the Seal Ring in

DH-V1.

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(2)

ER 76-41/3L, Empty Fluid Reservoir of the Hydraulic Shock

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and Sway Suppressor located in Position RC-14.

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(3)

ER 77-01/1T, the "A"

Diesel Generator, DG, would not start

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in the event of an offsite power loss without an ES signal.

c.

The inspector's findings were acceptable except for those

Unresolved Items delineated below.

Also, inspection findings

relative to additional information concerning these events are

summarized, as appropriate.

(1) With respect to ER 76-40/3L:

On November 6,1976, the

body to bonnet seal ring on the Decay Heat Isolation

Valve, DH-VI, which had been leaking .2

.5 gpm, began

to leak excessively during a plant cooldown.

This valve

is normally closed during power operation and the increased

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leakage resulted when the valve was opened to provide

cooldown of the reactor coolant system.

The valve is not

isolable from the reactor coolant system and, therefore,

will require an extended shutdown to make permanent

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repairs.

The licensee chose to effect a temporary repair

until the next refueling outage.

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An engineering evaluation of the problem determined that

an acceptable repair could be made by drilling four

holes, 90 apart, through the valve body in the area of

the seal ring.

This would provide access to the thread

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relief area directly above the seal ring gasket and below

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the retaining ring. A commercial sealing compound,

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"Furmanite," would be injected through special adapters

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threaded into the drilled holes.

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The licensee engaged a consulting firm to evaluate this

method of repair.

The consultant performed a stress and

fatigue analysis of the effect caused by drilling the

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holes and found them to be acceptable within ASME Code

established criteria.

The consultant also suggested

that, as a result of the chemical analysis performed by

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the licensee showing a leachable chloride content of 50

l

<g

PPM and a total chloride content of 1300 - 1700 PPM, the

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nuclear steam system supplier (NSSS), Babcock and Wilcox,

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be consulted concerning the advisability of injecting

Furmanito. The concern was the increased potential for

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stress corrosion cracking (SCC).

The final recommendation

cf the consultant was to use the Furmanite.

The NSSS letter, dated November 4,1976, advised that,

due to the critical location of the valve and the relatively

high chloride content, they could not recommend the use

of Furmanite.

Concurrently, the licensee stated that the laboratory, on

running a blank sample to verify the chloride chemistry,

found the background contamination of chlorides to be 50

PPM.

Considering this, the laboratory felt that the

actual chloride content was approximately 5-8 PPM.

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The licensee's staff reviewed the various recommendations

and decided to use the Furmanite due to the reduced

chloride values reported by the laboratory and the other

positive factors such as:

(1) the known low operating

temperature of the valve,1400F; (2) the corrosion resis-

tant characteristics of 316 stainless steel; (3) the

low oxygen content of the reactor coolant water; and (4)

if the leak is completely stopped the area exposed to

water will provide very low quantitites of leachable

chlorides and no evaporating mechanism for concentrating

the chlorides, thus, minimizing SCC problems.

The staff

also recommended the following restrictions:

(a) The valve be repaired at the next refueling outage.

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(b) The valve (seal ring area) be completely sealed with

Furmanite so that leakage does not cause vapor con-

densation.

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(c) The temperature of the valve does not exceed 100 C

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and naterial temperatures are kept as far below that

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as possible.

([)

The procedure using the Furmanite repair method was approved

by the Plant Operation Review Committee on November 7,1976,

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and the leak was successfully repaired.

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The inspector rev tewed the above described repair program

and was informed by the licensee that plans are now being

made to leave the Furmanite repair in place beyond the

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next refueling outage for some extended period of time.

The licensee also stated that further engineering evalua-

tions are being incorporated into a report that is to be

issued within the next 2-3 weeks.

This item, 77-05-02, is considered unresolved pending the

NRC's review of the licensee's supplemental engineering

report and the valve repair schedule.

This review will be

completed prior to facility restart following the forth-

comina refueling outage.

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(2) With respect to ER 76-41/3L:

During routine surveillance

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of the snubber located inside the Reactor Building Secon-

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dary Shield wall, one snubber at position RC-14 on the

pressurizer spray line was found with an empty fluid

reservoir.

The inspector was shown the removed seals.

.

Discussions with licensee personnel indicated that the

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seals were damaged due to improper assembly. Also, one

seal was missing.

The action by the licensee is in agree-

ment with the Current Surveillance Procedure 1301-9.9,

Hydraulic Shock and Sway Suppressors, Revision 6, dated

July 15, 1976.

The procedure is performed to insure that

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the hydraulic shock and spring suppressors used in safety

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related systems are in proper operating condition.

The

procedure calls for surveillance to be increased as a

function of identified failed suppressors during a sur-

veillance.

The inspector has no further questions on this item.

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(3) With respect to ER 77-01/1T: On February 2, 1977, the

licensee determined that the "A" DG would not have suc-

Q

cessfully started in the event of a loss of Offsite Power

unless an ES signal was present.

The oil pressure low

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speed (OLPS) switch was found to be stuck. When the OPLS

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switch failed to operate before the cranking timer operated,

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a start failure signal occurred that tripped off the DG.

If an ES signal is present this trip signal is defeated

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and the DG would have started.

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Diesel Generator "A" was tested and found operable on

February 1.

On February 2,1977, the "A"

DG was found

inoperable and it was concluded that the OPLS was or may

have been stuck for a period of time in excess of that

allowed by TS 3.7.2.c because DG "B" was tagged out for

maintenance.

The licensee will change the time setting requirements

once new OPLS switches are installed.

Procedure 1301-8.2

will be changed to reflect the new time settings.

This is an unresolved item (77-05-03) pending the comple-

tion of the corrective actions.

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4.

Seismic Qualification of Steam Generator Level and Pressure

Indications, Unit 1

References: NRC Inspection Reports 50-289/76-10, Detail s, para-

graph 6, 50-289/76-24, Details, paragraph 5.j , and licensee's

letter dated December 16, 1976 (GQL 1692.)

The inspector reviewed the Nonconformance Report No.76-362 which

identified 5 discrepancies with the Nonnuclear Instruments /Inte-

grated Control Systems (NNI/ICS) which were being modified to

upgrade their seismic classification (see reference reports.)

The inspector verified that all discrepancies had been addressed

by the engineering staff in a letter dated January 4,1977, and all

items were satisfactorily resolved.

The inspector had no further

questions.

5.

IE Bulletin / Circular Followup, Unit 1 (except where noted)

IE Bulletins /Circalars discussed below were reviewed to verify that:

!

Licensee management forwarded copies of the response to the

--

p/

bulletin / circular to appropriate onsite management representa-

.

tives.

(

,

'

Information discussed in the licensee's reply was cupported by

--

,

facility records or by visual examination of the facility.

!

Corrective action taken was effected as described in the reply.

--

The licensee's reply was prompt and within the time period

--

described in the bulletin / circular.

The review included discussions with licensee personnel and obser-

vation and review of items discussed in the details below.

The licensee's actions and response concerning IE Bulletin / Circular

followup were acceptable.

Additional actions required by ta licen-

see are noted as unresolved items.

a.

Bulletin 76-06, Diaphragm Failure in Air Operated Auxiliary

Actuators for Safety / Relief Valves (IEB76-06).

References:

IE Bulletin, July 21, 1976; Licensee's Response dated July 30,

1976.

1483'025

e

. . - .

-

.

. - . .

-.

..-

.

i

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!

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15

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()

i

~

This kulletin deals with auxiliary air actuator diaphragms,

composed of dacron fabric reinforced silicone rubber, being

degraded.

The licensee's response indicated that there are no valves

which are considered to be in the category of safety related

diaphragm operated relief valves in high temperature systems.

The inspector discussed the design of the safety related

I

relief valves with the cognizant licensee engineer.

The

!

valves in use at TMI-1 are not insulated and operate by

mechanical linkage.

PORC minutes for PORC Meeting No. 345,

7/26-30/76 were reviewed.

The minutes indicated that the PORC

j

agrees with the negative response.

I

The iisspector has no further questions on this item.

!

j

b.

Circular 76-06, Stress Corrosion Cracks in Stagnant Low

Pressure Stainless Piping Containing Boric Acid Solution at

,

i

PWR's (IEC 76-06).

References:

IE Circular 76-06, November

24, 1 976; Licensee response dated December 29, 1976.

!

This circular deals w'ch through wall cracking that has occurred

in 304 stainless steel piping at PWR Nuclear Power Plants.

Similar failures were not found at TMI-1.

Th'e failures have

I)

been attributed to intergranular stress corrosion cracking

'

1

initiated on the inside wall of stainless steel piping.

The licensee was requested to describe their program to aseure

the integ ity of similar stainless steel piping.

i

,

The response by the licensee indicated that they have an ongo-

ing program of monitoring chloride levels in systems naving

similar characteristics of those having failures found at

other PWR's.

Current results indicated that chloride content

is less than 1 ppm in the following systems:

,

Decay Heat System

Borated Water Storage Tcnk

Reactor Coolant Bleed Tanks

Core Flood Tanks

Spent Fuel Pool

The inspector reviewed the Chemistry Log.

The following sur-

veillance data was recorded:

1483 026

m

_.

-

.

__

_

__

__

__.

._

!

- '

16

,

+

,

(l

Decay Heat System - for daily checks between November 14,

--

1976 through November 18, 1976, chloride ppm ranged from

0.09 to 0.30 ppm.

l

l

Borated Water Storage Tank - for November 13, 1976, not

--

i

detectable; December 13, 1976, not detectable.

Reactor Coolant Bleed Tanks - for November 16, 1976, B

--

Tank, 0.01 ppm; November 19, 1976, A Tank, not detectable;

November 20, 1976, B Tank, 0.08 ppm; November 21, 1976, C

Tank, 0.06 ppm.

iore Flood Tanks - for December 16, 1976, A Tank 0.05

--

ppm, B Tank 0.06 ppm; November 16, 1976, A and B Tank,

not detectable.

Spent Fuel Pool - for October 30, 1976, not detectable;

--

November 13, 1975, 0.06 ppm.

,

The licensee has stated that in the event chloride levels are

found to be at a threshold chloride value for stress corrosion

cracking (Reference:

Stress Corrosion Cracking of Iron-

()

Nickel-Chromium Alloys, R. M. Latanision and R. W. Staehle,

p

Ohio State University - publication,) special testing of the

piping involved will be considered.

-

The licensee will perform hydrostatic testing of the Reactor

Building Spray System in accordance with ASME Section XI

during the next refueling outage (scheduled to begin March 19,

1977.)

During the special test an ultrasonic examination will

be performed on the Reactor Building Spray piping.

At least 4

selected welds will be volumetrically examined in accordance

with ASME Section XI, Appt.' dix I, except that the examined

area will cover a distance of 6 times the pipe thickness but

not less than 2 inches nor more than 8 inches.

The special

test procedure will include the use of Surveillance Procedure

1300-IE, Revision 1, December 23, 1976, Manual Ultrasonic

Examination of Reactor Coolant and Associated Piping Welds.

1483 027

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17

)

The special test procedure remains to be written and approved.

This is an unresolved item (77-05-04) pending the completion

of the procedure.

The IE Circular response transmitted by the licensee is cur-

rently being reviewed along with responses from other PWR

licenstes. A final decision on the adequacy of the response

bas not been made.

This is an unresolved item (77-06-13)

pending the final decision by NRC.

4

c.

Circular 76-05, Hydraulic Shock and Sway Suppressors - Mainten-

ance of Bleed and Lockup Velocities on ITT Grinnell's Model

Nos. - Figure 200 and Figure 201, Cutalog PH-74-R (IEC 76-05).

References:

IE Circular 76-05, Octouer 8, 1976; Licensee's

response dated January 5, 1977.

This circular deals with spectfic Suppressors and specifically

identified plants informed by ITT of a problem.

It further

'

requests the review by the licensee to assure that in the

,

event they have the identified suppressors that corrective

i

actions be performed.

l

O

The iicensee's response indicates enat the suspect suppressors

'

(

are not in use at TMI-1.

The inspector reviewed the licensee's

.

documentation listing the suppressors in use at TMI-l.

This

,

{

included Gilbert Associates - Snubber deal Replacement Matrix

for Three Mile Island Unit 1 and the Snubber History (WR 4438)

'

Fil e.

The same documents were reviewed by the licensee.

.

There was no indication that serial numbers B0001 through

'

B2000 are used at TMI-1.

This item was reviewed by PORC and documented in PORC Meeting

No. 367, December 27-30, 1976.

The inspector has no further questions on this item.

d.

Circular 77-01, Malfunction of Limitorque Valve Operators.

Reference:

IE Circular 77-01, January 6, 1977.

This circular requested that the licensee check his procedures

for proper precautions to be taken when closure of, torque

limit switch equipped valves are closed manually.

The pro-

cedures should address the following:

1483 028

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.

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( I

Checks of operability following maintenance

--

Checks on manual closure

--

Personnel instructed to conform to procedures

--

Assure that bypass limit switch was not negated.

--

No response to this circular was required.

The inspector re-

viewed the actions taken by the licensee.

Procedure 1420-LTQ-2, Limitorque Operator, Limit Switch Adjust-

2

ment, Revision 0, April 2,1975, was reviewed.

The purpose of

this procedure is to provide instructions for the proper

settings of Limitorque Limit Switches.

Also, procedure 1420-

LTQ-3, Limitorque Saitch Adjustment, Revision 0, May 28,1975

,

was reviewed.

tieth procedures have been changed, reference

change requests Nos.77-058 and 77-059.

The changes include a check on the bypass limit switch, post

maintenance checks including dynamic checks to assure settings

l

are correct and the valve operable under operating conditions.

()

The procedure changes have been reviewed by PORC, reference

~

PORC Meeting 77-06.

Corrective action on the above procedures

i

apply to Unit 1 and 2.

The final revised procedures remain to be revised.

This item

'

77-05-05 is unresolved pending the final revision completion

of these procedures.

,

6.

Safety Limits, Limiting Safety System Settinos and Limiting Conditions

for Operation, Unit 1

a.

Reactor Coolant System

(1) TS 2.1.1 Reactor System Pressure and Temperature Limits,

as reflected in Figure 2.1-1 were reviewed for compliance.

Recorded data for the heat-up evolution attached to

0

operating procedure 1102-1, Plant Heat-Up to 525 F,

dated November 17, 1976 file, verify that the limits were

not exceeded.

1483 029

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.

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_ _ .

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-.

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n.

19

(l

.

(2) TS 3.1.2.1 for heat-up were reviewed for the November

heat-up evolution.

The computer trend analog trace data

for temperature and pressure were reviewed.

The data as

plot' ?d on Figure 1, November 18, 1976, of operating

procedure 1102-1 were checked.

The heat-up rate was

within limits.

b.

Reactivity and Power Control

(1) TS 3.5.2.1, limits on the available shutdown margin, was

reviewed.

The filed recorded work sheet, November 19,

1976, was reviewed.

The worth determinations indicated

that the required limits were met.

(2) TS 3.5.2.5, control rod positions, was reviewed for the

2

period February 6-14, 1977.

Data is contained in Sur-

veillance Procedure 1302-1.4, Shift Daily Checks.

The

data was compared to TS Figure 3.5-2B.

The rod positions

were found to be within the required limits for the

period of operations reviewed.

i

c.

Power Conversion and Auxiliary Systems

(3

i ('

(1) TS 3.1.1.2 requires that one steam generator be operable

'

whenever the reactor coolant is above 250 F.

Operating

!

Procedure 1102-1, record for December 3,1976, and Sur-

veillance Test 1303-5.4, Emergency Feedwater Pumps were

reviewed. The Surveillance Procedure is performed to

verify that the turbine driven emergency feed pump (EF-

P1) and associated valves are operable in accordance with

TS 4.9 and to verify that the two motor driven emergency

'

feed pumps (EF-P2A and B) and associated valves are

operabl e.

The Surveillance Test 1303-5.4 contained a deficiency for

the test performed witn respect to valve EF-P2A.

D1scus-

sions with the Shift Foreman indicate that the valve was

manually operable and in the required open position.

(2) TS 3.4.6 requires all eighteen steam safety valves to be

operable; if r.ot a power penalty is imposed.

Verifica-

tion of steam safety valve operability is confirmed by

1483 030

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-

acceptable performance of Surveillance Test 1303-11.3,

'i

Main Steam Safety Valves, Revision 2, November 13, 1975.

!

The purpose of this procedure is to verify the setpoint

!

of the main steam safety valves, MSSV, MS-V-17A, B, C, D,

j

MS-V-18A, B , C , D, MS-V-19A, B , C , D, MS-V-20A , B , C , D ,

and MS-V-2'.A, B.

This test is performed to meet TS 4.1.2, Table 4.1-2, item 4.

,

Twenty five percent of the valves must be tested during

l

each refueling period.

The data of February 14,1976 was

reviewed. Valves MS-V-18A, MS-V-19A, MS-V-20A and MS-V-

j

21 A were tested satisfactorily.

l

d.

Containment Systems

(1) TS 3.6.4 requires that the reactor building pressure be

less than 2 psig and greater than 1 psig vacuum when the

plant is critical.

Surveillance procedure 1301-1, Shift and Daily Surveillance

Checks, Revision 2, dated April 17, 1974 was reviewed for

._

2/9,11,13,15, and 24/77.

The control room pressure

t.

meter was also checked on February 24, 1977.

The contain-

i()

ment pressure limits were found to be within limits.

(2) TS 3.6 applies to the containment integrity of the reactor

i

building.

Operating Procedure 1101-3, Reactor Building Integrity,

Revision 11, dated September 17, 1976 was reviewed for

+

November 18, 1976.

The procedure was completed and the

containment secured.

I

l

e.

Electrical Systems

'

(1) TS 3.7.1.e requires 25,000 gallons of fuel oil in the

storage tank prior to criticality.

The inspector visually inspected the control room indica-

tors. The panalarm was off indicating oil content above

the required minimum.

Procedure 1102-2 Three Mile Island

Plant Startup, records for December 3,1976 were reviewed.

The records indicate, step 28, that the required fuel was

available prior to criticality.

-

1483 031

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<1

.

(2) TS 3.7.1.f requires that the batteries are charged and in

service prior to criticality.

Procedures 1102-2, step

29, and surveillance procedure 1301-4.6, Station Storage

Batteries, Revision 2, dated September 10, 1975 were

reviewed. The purpose of the surveillance procedure is

to insure that the storage batteries are maintained in a

fully charged condition and also meet TS 4.6.2.b.

The

data sheet for January 7,1977 was reviewed and found

satisfactory.

f.

Emergency Core Cooling Systems

(1) TS 3.3.1.1.a requires that the Boric Acid Water Storage

tank contain a minimum of 350,000 gallons of 2,270 ppm

boron at a minimum of 400F prior to critical .

Procedure 1102-2 records for December 3,1976 were reviewed.

l

Step 7 verifies that TS 3.1.1.a was met. Baron concentration

of 2296 ppm, temperature 880F.

The inspector also noted

,

l

the control room readings for February 24, 1977.

The

!

indicators, DH3-LIl and LI2 indicated levels above the

l

minimum for the 350,000 gallons of solution in the tank.

s

'

()

I

(2) TS 3.3.1.2.c requires the Core Flood Tank discharge

(' )-

valves to be open prior to criticality and so indicated

on the control room ES panel .

Respective breakers for

4

these valves, CFV-1A and CFV-18, shall be open and marked.

I

The inspector reviewed procedure 1102-2 records for

December 3, 1976, step 20, page 39, for prior to critical

valve status.

Documentation indicated that the correct

positions of the valves were established.

The inspector

,

visually verified that on February 24, 1977 ES indication

showed the valves to be in the open position.

The breaker

panel, CES, in the Auxiliary Building was inspected.

The

breakers were found in the open position and marked with

tags no. 33 and 32 respectively.

The tags were checked

against the tag log and found to agree. The panalarm

indicator was out which also indicates the valves were in

the correct position.

The inspector noted that the ES

indicators for these two valves had yellow background and

were the exceptions for color coded recognition of required

position status. The licensee personnel know this as an

exception.

In the interest of minimizing error, the

licensee intends to review the reasons for this exception.

-

1483 032

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.

7

22

7.

Review of Plant Operations

a.

Shift Logs and Operating Records

The inspector reviewed records listed below, held discussions

with plant staff members, and inspected the control room on

February 24 and 25,1977.

(1) Shift and Daily Check: SP 1301-1 for the period February

1-15, 1977, and the Control Room Log Sheet for the period

of January 25 through February 13, 1977 were reviewed to

verify that:

(a)

Log sheets are completed properly;

'

(b)

Log sheet reviews are being conducted.

Findings were acceptable.

1

The inspector noted that the limits on the log sheet are

,

I

more stringent than required by TS.

This is acceptable;

,

I

however, when the limits on the log sheet are not met,

but are accepted on the broader basis, future problems

'

-

could result.

This kind of detail, to have the noted

criteria agree with the attainable and acceptable values,

4

was discussed with the licensee, and he agreed to look

'

into this potential problem area.

The content of the Shift and Daily Check was discussed

with the licensee, ami he agreed that consideration would

be given to includin; s'le TS reference and/or the spedfic

TS requirement for the parameter being recorded on the

check sheet.

.

These items will be reviewed during a subsequent inspection,

'

and the matter is designated as an Inspector Followup Item

(77-05-13.)

(2)

Primary Auxiliary Operators Log - Tour Readings: Entries

for the period January 25 through February 13, 1977 were

reviewed for completeness and details adequate to commun-

icate equipment status.

Findings were acceptable.

1483 ,033

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(3) Operating Orders:

The active SOP Book was reviewed and

it contained SOP's 453, 455, 456, 457, 458, 459, 461,

-

462, 263, 464, and 465.

No conflicts with TS require-

ments were observed,

b.

Tour of Accessible Areas

The inspector observed operations in the control room and

toured various levels of the Intermediate, Auxiliary and Tur-

bine Buildings and the Control Room Tower on February 24 and

25, 1977. The following observations were made and discussed

with plant staff members, as appropriate.

(1) Monitoring Instrumentation:

Control room indications

and/or records for BWST level, temperature and baron con-

centration, CFT pressure, level and boron concentration,

Sodium Hydroxide Tank and Sodium Thiosulfate Tank contents

and temperature, Control Rod Index, Nuclear Power Axial

Power Imbalance, Reactor Coolant flow, pressure and

.

outlet temperature. R& actor Building pressure, wind speed

l

and direction and River Water AT were examined, and no

discrepancies with Technical Specification LCO's were

'

)

-

observed. Additionally, Shutdown Panel ir.iications were

observed to be consistent with Control Room indications.

(2) Radiation Controls: Areas within the Auxiliary Building

were observed to be properly posted and controlled.

How-

ever, a problem area was identified.

Namely, there are

numerous individual roped off areas (Radiation and/or

Contamination Areas,) e.g. El 281', and entry into these

.

areas is controlled by a separate RWP. However, pro-

tective clothing (required by a RWP for each area) was

not readily available at each entry point.

This practice

required an operator to carry around several sets of pro-

tective clothing in order to enter those areas which

require an operational type inspection or surveillance,

or to perform an equipment operation.

The licensee agreed to evaluate this matter, and it is

designated as an Inspection Followup Item (77-05-14.)

.

1483 034'

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24

(3)

Plant Housekeeping Conditions: Storage of mate'eial and

components ras observed with respect to prevention of

safety and f're hazards.

No adverse conditions of inmed-

iate safety cancern were identified; however, areas where

the need for b usekeeping improvements is indicated were

discussed with ilant and corporate management.

These

areas were ati. ibuted to a lack of administrative require-

ments, as discussed in Detail 9.k.

(4)

Existance of Fluid Leaks:

Fluid leaks observed had

already been identified by the licensee for future main-

tenance action.

(5)

Existance of Piping Vibrations: No excessive piping

vibrations were observed.

(6)

Eipe Hangers / Seismic Restraints: About 20 snubbers on

the Main Steam, Emergency Feedwater, and Reactor Building

spray systems were observed for proper fluid levels, 'nd

no adverse conditions were identified.

()

A partially filled plastic squeeze bottle of snubber

fluid was found at El 281' of the Auxiliary Building; the

bottle was not identified and was not controlled.

This

matter was discussed with the licensee, and he agreed to

establish procedural controls for snubber fluid and other

safety related consumable material, e.g., diesel generator

,

lube oil, lubricant, etc., as necessary, following with-

drawal of these items froin stores by plant personnel.

This item (77-05-06) is unresolved pending completion by

the licensee and review by a NRC:I inspector.

(7)

Valve Positions / Equipment Start Position Switches:

Valves DH-VISA, BS-V53A, BS-V49A, BS-V54A, BS-17A, BS-

178, BS-41B, BS-498, and BS-V548 were observed to be

locked open, and -valves DH-V38A and DH-V38B were observed

to be locked closed in accordance with procedural require-

ments.

Additionally, valves CF-VIA and CF-V1B were

observed to be open and red tagged in accordance with TS 3.3.1.2.c.

1483 035

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.

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(8)

Equipment Caution / Lockout Tag Infctmation: The active

tag log was reviewed and the tagging associated with

valves CF-VIA and CF-V1B (#32 & 33,) RM-A6 (#1747,) and

a containment Building Emergency Ventilation Supply Fan

(#1745) was selected for further review.

No discrepancies

,

relative to approval and placement of tags were identified.

Additionally, the inspector observed the placement of tags

]

  1. 1745 and #1747 by shift personnel.

1

(9) Plant Tour: The licensee's administrative policy and

'

practice regarding plant tours conducted by the Unit

Superintendent and the duty Shift Supervisor were deter-

.

mined. Although there are no administrative requirements

'

!

in this area, the inspector determined by discussions with

these individuals that plant tours are made by the Shift

- ,

Supervisor at least once per shift and by the Unit Superin-

tendent as often as possible consistent with his work load.

(10)

Control Room Manning: The inspector observed that the

day and swing shifts were staffed and the Control Room

was manned in accordance with TS 6.2.2 and 10 CFR 50.54(k).

l

i

'

(11) Maintenance Item: The ir.spector observed maintenance per-

sonnel working on the valve operators of MS-V10A and MS-

i108. The personnel were using an approved Work Request

!

(WR 19011,) the maintenance foreman was present, and the

Shift Supervisor was aware of this maintenance task. The

'

inspector had no further questions on this matter.

i

(12)

Jumper Control: The inspector observed that a Jumper (#20)

was installed in Junction Box T661 between terminals 17D

and 200.

This was discussed with the duty Shift Supervisor,

who was aware of the jumper installation. A subsequent

review of the Jumper Log revealed the jumper had been

installed and was being controlled in accordance with

AP 1013.

The inspector had no further questions on this

matter.

8.

Corrective Action for pt eviously Identified Enforcement Items

a.

Item 76-11 (Detail 3)

The licensee's actions for this item were described in Met Ed

letters dated June 21,1976 (GQL 0882,) September 30, 1976

(GQL 1372,) and Noverr'er 12,1976 (GQL 1579,) and these actions

]

were to be completed tey November 24, 1976.

1483 036

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.

.-

. . -

.

!

26

-

Based on review of the PORC closecut form for this item, PCR

76-532 and related review comments from the Manager, Operational

Quality Assurance (M0QA ) and discussions with plant personnel,

the inspector determined that the licensee's comitments, as

stated in the referenced correspondence, had not been completed

as of February 25, 1977.

PCR 76-532, which affects AP 1001,

had been reviewed by the Unit 1 PORC and the Unit 2 PORC, had

been approved by the Unit 1 Superintendent and the Unit 2

Superintendent, and had been sent to the Corporate Office on

October 12, 1976 for approval by the Manager, Operational

Quality Assurance, M0QA.

Following review by the M00A, PCR

,76-532 was returned to the site on October 28,1976 for

resolution of the M00A's comments.

The status of PCR 76-532

,

had remained unchanged since that time.

Completion of the licensee's corrective action will be reviewed

during a subsequent inspection, and this item (77-05-07) is

unresolved.

!

b.

Item 76-19-2

i

The licensee's actions for this item were described in a Met

t

)

Ed letter dated September 21, 1976 (GQL 1318,) and these

actions were to be completed on August 27, 1976 and November

,

1

1, 1976.

Based on review of the PORC Closeout Form for this item, NCR

76-372, and discussions with plant personnel, the inspector

determined that the licensee's commitments, as stated in the

referenced correspondence, had been completed for the August

27, 1976 action item, but had not been completed for the

November 1,1976 action item as of February 25, 1977.

Docu-

mentation of the training of Mechanical Maintenance personr.el

could not be located, but the inspector was informed that this

training had been completed by November 1,1976.

Training of

I&C and Electrical Maintenance personnel had not been completed

according to plant personnel, and that the documentation of

those personnel who had completed the training was stili in

circulation within the respective groups.

Completion of the licensee's corrective action will be reviewed

during a subsequent inspectf x , and this item (77-05-08) is

unresolved.

_

1483 017

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_-

.-.

-

.

.

27

The licensee's failure to take corrective action in accord-

ance

-

bis commitments to NRC:I, as described in subpara-

' ra n...

L c .

b, is contrary to the requirements of 10 CFR 50,

,

' pendi. D,

riterion XVI and the accepted Operational Quality

.

Assurance Plan (FSAR Section IA) Section 6.7.

This Item of

' .ncompliance (77-05-08) is an Infraction.

c.

Item 76-25-1

In his response letter dated Decembe; 8,1976, the licensee

documented corrective actions for this item which was identified

in enforcement correspondence to the licensee dated November

'

18, 1976.

The inspector reviewed the licensee's records for

fire extinguisher inspections conducted in December 1976 and

January and February 1977.

This inspection assignment was with

the Mechanical Maintenance Department at the time of the inspec-

tion although the licensee's response had indicated that the

inspection duties might be reassigned to the TMI Safety Super-

visor.

The inspector had no further questions.

9.

Previously Reported Unresolved /Other Items

\\

l.

a.

GORB Review of TS and License Violations

Reference: NRC:I Inspection Reports 50-289/76-01, Detail

13.b.(8) and 50-289/76-17, Detail II.11.

Based on review of GORB Meeting Minutes (Draft) for Meeting

No. 25 conducted on December 8-9, 1976, the inspector deter-

mined that the Items of Noncompliance delineated in NRC:I

Inspection Reports 50-289/75- 01, 04, 06, 08, 13, 14, 15, 20,

and 23 had been reviewed.

This item is resolved.

b.

Radiation Chemistry Technician Training on Procedure HP 1631

Reference: NRC:I Inspection Report 50-289/76-10, Detail

3.b.(1)(b).

1483 038

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.

-

-

-.

-_

-

.

m

( ,

28

Based on review of training records maintained by the Acting

Supervisor of Radiation Protection and Chemistry, the' inspector

determined that the 18 technicians had received training on

Procedure HP 1631. Additionally, this procedure had been

revised (Revision 1, dated December 16,1976) to provide a

detailed checklist covering operations.

This item is resolved.

c.

GORB Review of TS and License Violations

Reference: NRC:I Inspection Report 50-289/76-10, Detail 8.b.(4)

and 50-289/76-17, Detail II.10.d.

Based on review of GORB Meeting Minutes (Draft) for Meeting

No. 25 conducted on December 8-9, 1976, the inspector determined

that the Items of Noncompliance delineated in NRC:I Inspection

Reports 50-289/76-02, 03, 11, 13, 15, 16, 17, 18, 19, 20, 21,

and 24 had been reviewed; however, the 3 Items of Noncompliance

delineated in NRC:I Inspection 50-289/76-03 had not been reviewed,

and these items will be reviewed in the next GORB Meeting)(Sche-

duled for March,1977.)

This item (redesignated 77-05-09

remains unresolved.

'

d.

Reactor Building Purge System

Reference: NRC:I Inspection Report 50-289/76-15, Detail 21.

,

Based on review of procedures RP 1501-1 (Revision 2 ) RP 1501-2

(Revision 1,) and SP 1303-10.1 (Revision 3,) the inspector

determined that the subject procedures had been revised in

accordance with TS requirements on January 14, 1977 to include

those items previously identified by a NRC:I inspector.

This item is resolved.

e.

Record Storage Inadecuacies

Reference: NRC:I Inspection Report 50-289/75-14, Detail 12.b.

Detail 12.b of the referenced Report identified an Unresolved

Item with respect to licensee action to correct record storage

inadequacies which had been identified in the Chemistry, Health

Physics, and Operations Departments during the licensee's con-

duct of his audit 75-10.

These specific inadequacies had been

corrected.

The item is resolved.

1483 039

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._.

_

_

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.

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$

29

However, in review of the corrective action on this audit

(75-10,) the inspector identified that finding number 2

remained uncorrected as of February 25, 1977.

This finding,

which documented a failure to review records prior to storage,

was first given a due date for completi

of June 15, 1975.

This date was subsequently extended to July 30, 1976; October

30, 1976; and most recently to January 15, 1977.

The licensee's

grarting of numerous extensions was the subject of Unresolved

Item 75-24-12 (see below.)

The action for an overdue commit-

.

ment date based on the January 15, 1977 date has not yet been

,

required based on the licensee's approved precedure.

The

completion of corrective action for Unresolved Item 76-24-12

should prevent recurrence of this number of extensions.

The

licensee's procedure for overdue commitments should resolve

this finding if followed.

Until Finding 2 of Audit 75-10 is closed, this item (77-05-10)

is unresolved.

The following, Previously Reported Unresolved Items,

--

were recorded in NRC:I Inspection Report 50-289/76-24:

l

O

f.

Item 76-24-2, FSAR Change for RCP Monitor Delay Time

Based on review of Revision 2 to the FSAR dated January 28, 1977,

as posted in Controlled Copy No. 9, the inspector determined

i

that page 14-66a of the FSAR had been revised to include the

new B&W analysis.

i

l

This item is resolved.

g.

Item 76-24-3, Additional Evaluation of ER 76-18/1T

Based on review of the licensee's evaluation (GEM 3443 and

PORC Meeting Minutes,) the inspector determined that the

analysis documented in ER 76-18/1T used the correct fuel den-

sification penalty.

This item is resolved.

1483 040

~

.

G

_.

.

.-

-.

.-

..- - - -.

_

- . . . . .

-

.

.

,

30

h.

Item 76-24-4, Repair of Valve MU-V2B

Based on review of completed Work Request WR 15772 (Signed

off on December 7,1976) and discussions with plant personnel,

~

the inspector detennined that the valve operator had been

repaired, the valve had been satisfactorily tested, and that

no recurrent problems had been experienced.

This item is resolved.

i.

Item 76-24-5, Long Term Corrective Action for ER 76-28/4___T

and 76-35/lT

Based on review of Interoffice memoranda (GQM 3225, dated

i

November 1,1976, and GNM 3280, dated November 8,1976),

discussions with plant personnel and observations of Control

'

Room indicators, the inspector determined that the licensee

had established and implemented new guidance concerning

control of the river water discharge temperature which pro-

j

vided more operational flexibility while complying with re-

quirements and that no recurrent problems had been experienced.

!

()

This item is resolved.

'

j.

Item 76-24-10, GORB Review of Reportable Occurrences

j

Based on review of GORB Meeting Minutes (Draft) for Meeting

No. 25 conducted on December 8-9, 1976, the inspector deter-

,

!

mined that ER 76-16/3L, ER 76-26/3L, ER 76-30/3L, and ER

76-31/3L, as well as numerous other event reports, had been

'

revie'ed.

This item is resolved.

k.

Item 76-24-11, Housekeeping Procedure

Based on review of NCR 76-386, which tracks

1 findings of

QC Surveillance Report 76-192, discussions -

.. lant per-

sonnel and observations of housekeeping condicions, the

inspector determined that the licensee's corrective action to

achieve compliance with ANSI N45.2.3 was in progress, but not

1483 041

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_ - .

-

.

%

31

-

yet completed, i.e., the housekeeping procedure had been

reviewed by the PORC on two occasions, and there were still

major comments to be resolved.

The commitment date to resolve

the NCR had been extended from December 1,1976, to March 1,

1977, in accordonce with the established QA procedure; however,

the Unit 1 Superintendent informed the inspector that the

March 1,1977, date would not be met due to the workload

involved with the refueling outage (scheduled to begin March

19, 1977) and the work necessary to integrate the housekeeping

requirements into the same procedures being developed for Fire

Prevention / Protection.

To resolve this matter in the interim and for the long term,

the Unit 1 Superintendent made the following commitments to

NRC:I during the exit interview:

(1) 3y March 5,1977, written administrative controls would

be established to designate all no smoking areas and all

areas where control of combustible material is required.

I

(2) Management attention would be focused on present house-

j

keeping conditions and practices to achieve improvements

-,

!

()

on a continuing basis while development / approval of the

!

~

housekeeping procedure progressed.

'

(3) By April 15, 1977, the administrative procedure governing

housekeeping activities would be approved and in use.

This item remains unresolved and is designated as item 77-05-

11 for future inspection followup.

1.

Item 76-24-12, Revision of Procedure GP 4015 to Include

Criteria on Due Date Extensions

Procedure GP-4015, Revision 3, dated December 27,197.6, now

includes specific criteria on granting extensions when an

established audit finding corrective action completion date

can not be met.

This item is resolved.

1493 042

.

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-

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- - - -

_

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- - -

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32

s

l

.

m.

Item 76-24-13, Revise Procedure GP 4015 to Include

Criteria on Closecut

Precedure GP 4015, Revision 3, dated December 27, 1976,

now includes specific guidance on verification of comple-

tion of corrective action on audit findings before listing

the finding as closed.

i

This item is resolved.

I

n.

Item 76-24-14, Verify that Audit Report 75-32 is Available

i

at Site QC Files

!

l

Audit Report 75-32 was available in the site QC files as

required.

,

!

This item is resolved.

i

o.

Item 76-24 J15, Revise GP 4407 to Designate Duplicate OC

Record Storage Requirements

Procedure GP 4407, Revision 1, dated January 13,1977, now

'

( ,/

,

i

includes designation of duplicate record storage require-

,

-

ments and locations.

'

This item is resolved.

p.

Item 76-24-16, Revise Procedure AP 1016 to Specify How

Modifications are Sent to Training

1

I

Procedure AP 1016 has been revised to document the current

methods used to notify training personnel when completed

modifications are to be included in the training program.

This procedure has been under review by the PORC since

November 1,1976.

During the referenced inspection, the

licensee had stated that this procedure would be revised

by January 3,1977.

During the exit interviews the inspec-

tors discussed the desireability of meeting commitment

dates documented in NRC reports.

The Unit 1 Superintendent

stated that commitment dates were given with the full in-

tention to have actions ccmpleted as stated.

The Manager

of Quality Assurance stated that only commitments documented

1483 043

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. - -

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33

in official correspondence to the Commission were considered

to be binding.

The inspectors stated that commitments docu-

mented in the inspection reports were considered as goals

to be met.

However, the inspectors stated that dates which

are considered as more than goals would be set out in the

letters which transmit the inspection reports.

Item 76-24-16 remains unresolved and is designated as item

77-05-01 for future inspection followup.

q.

Item 76-24-17, Verify Completion of Corrective Action on

NCR TMI-76-439

Procedure GP 4003, Revision 2, dated February 21,1977, re-

solved NCR TMI-76-439 by including the ANSI N45.2.6 quali-

fication requirements.

This item is resolved; however, as

with item 76-24-16, the date stated in the referenced report

for completion of this item was January 3,1977.

This item

-

was also referenced during the exit interviews as discussed

under item 76-24-16 above.

,

!

This item is resolved.

,

r.

CTSS Review of Facility Procehre Changas

Reference: NRC:I Inspection Report Numbers 50-289/76-01,

Detail 14.c. , 50-289/76-10, Detail 13.a, and

50-289/76-17 Detail II.10.a.

Based on review of the PCR Status Log and discussions with

a corporate staff member, the inspector determined the

current status of the PCR's covering 1974,1975,1976 and

1977, was as follows:

(1)

For 1974, of the 514 PCR's generated, 499 had been

reviewed,13 had been assigned for review, and the

remaining 2 had not been assigned.

(2)

For 1975, of the 544 PCR's generated, S20 had been

reviewed,19 had been assigned for review, and the

remaining 5 had not been assigned.

1483 044

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_ _ __

_

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. - -.--_-..- - -

.

34

!

C;

.

(3) For 1976, of the 831 PCR's gene:ated, 785 had been

reviewed,11 had been assigned for review, and the

remaining 35 had not been assigned.

(4) For 1977, of the 78 PCR's generated, 55 had been

reviewed, 13 had been assigned for review, and the

remaining 10 had not been assigned.

'

(5) The remaining 24 PCR's from the 1974-1975 backlog

which were deemed to have a significant affect on plant

operations had been reviewed.

The licensee is continuing to meet the comitments made to

NRC:I.

This matter will continue to be reviewed during sub-

sequent inspections, and it is designated as an Inspector

Followup Item No. 77-05-12.

10.

Procurement Control - Unit 2

a.

Administrative Controls

The inspector verified that the licensee has administrative

controls that equire procurement documents for safety-re-

lated items to provide for the following:

'

._

l

(1) Specific identification of equipment;

j

(2)

Identification of any test, inspection and acceptance

-

requirements;

(3) Raquisite technical requirements;

(4) Access to the supplier's plant or records;

(5) Requisite documentation to certify the item being

procured (Certificate of Conformance); and

(6) Contractor / supplier QA program.

1483 045

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The following procedures were reviewed for verification of

the above. Where verification was lacking it is so noted

as an unresolved item.

GP 1009, Revision 0, Procedure Document Control

GP 4005, Revision 1. Review of Procurement Documents

As e result of the above review, the following unresolved

item was identified:

i

77-09-02, With respect to the use of a Certificate of Con-

formance, in lieu of original records, ANSI M45.2.13, Section

10.2 requires that certain minimum documentation should be

supplied such as:

specific identification of purchased item;

--

the specific codes, standards or other specifications

--

,

met by the purchased item;

i

!

the identification of procurement requirements that

-m

--

!

have not been met; and

'

attestation by a person responsible for the supplier

--

QA function.

The licensee's procedures do not address the above minimum

documentation criteria for Certificates of Conformance.

b.

Procurement Measures and Responsibilities

The inspector verified that the licensee has administrative

controls that provide measures and assign responsibilities

in writing for:

(1)

Initiation of procurement documents;

(2) Review and approval of specifications differing from

original design documents;

1483 046

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36

t

(3)

Review and approval of procurement documents;

(4) Basis for designation of quality classification of pro-

curement items.

The following procedures were reviewed for verification of-

the above:

Gp 2009. Revision 0. Procuremetit Document Control.

--

,

GP 1011, Revision 1, Preparation, Charging, Updating,

--

and Issuance of Specifications and Bills of Material.

'

i

GP 4005, Revision 1, Review of Procurement Documents.

--

I

c.

Bidders / Suppliers

The licensee's procedures were reviewed to verify that adminis-

l

trative centrols provide for the following concerning bidders /

!

suppliers:

(

j

(1)

An acceptable method is established for " qualifying"

suppliers;

'

I

(2)

Provision for purchaser's right of access to supplier's

facilities and documents;

(3)

Maintenance of an " approved bidders" list;

.

(4) Maintenance of records of supplier qualification and audit.

The following procedures were reviewed for verification of

the above:

GP 0013, Revision 1, Evaluation and Qualification of Ven-

--

ders and Contractors.

GP 1016, Revision 0, Vendor Evaluation and Selection.

--

GP 4010, Revision 1, Approved Vendors List.

--

.

.

1483 0-4i7-

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37

9

)

11.

Receipt, Storage, and Handling, Unit 2

a.

Receipt Inspection

The licensee's procedures were reviewed to verify that admin-

istrative controls provide for the following concerning receipt

inspection of safety related items:

(1) Written requirements for conducting receipt inspections;

(2)

Requirements for receipt inspection of shipping damage;

(3)

Requirement that supplies will be examined for conformance

with requirements specified on original procurement docu-

ment;

,

'

(4)

Requirement that documentation of the receipt inspection

be prepared and retained.

i

The following procedures were reviewed for verifications of

the above:

e

o

)

GP 1009, Revision 0, Procurement Document. Control.

--

'

GP 4008, Revision 2, Receipt Inspection of Material and

--

Equipment.

b.

Disposition of Items

The licensee's procedures were reviewed to verify that the

following administrative controls provide for disposition of

items received onsite:

.

(1) Acceptable items including:

(a) Tagging / marking for storage;

(b)

Immediate issue for use.

(2) Nonconforming items including:

(a)

Marking and segregating;

(b)

Prohibiting the use of items in a " nonconforming"

status;

1483 048

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-- -.

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(c) Notifying affected organizations of nonconforming

items;

(d)

Documentation requirements.

(3)

Conditional release items including:

(a)

Justification for use;

(b)

Documentation required;

(c) Authority for conditional release of item.

The following procedures were reviewed for verification of

the above:

'

FSAR Section 17.2.12, Control of Purchased Material, Equip-

--

ment, and Services.

I

j

GP 4008, Revision 2, Receipt Inspection of Material and

--

-

Equipnent.

'

( 'l

AP 1018, Revision 2, Quality Control Warehousing.

-

--

,

c.

Storage

Stores Procedure No. 4, Material Storage, was reviewed to

verify that controls have been established for the following:

(1)

Levels of storage and appropriate environmental conditions;

(2) Storage controls including access, identification of items,

coverings, and preservatives;

(3)

Requirement to conduct periodic inspections of the storage

area;

(4) Maintenance and care of items in storage, including shelf

life.

1483 049

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.

.

39

,

-

I

d.

Material Handling

The licensee's procedures were r .iewed to verify that the

i

following administrative controls provide for handling safety

related material:

(1)

Routine and special handling measures are specified;

(2) Hoisting equipment controls are established.

The following procedures were reviewed for verification of the

above:

Stores Procedure No. 4 Material Storage.

--

,

FSAR Section 17.2.18 Handling, Storage, and Shipping.

--

12. Tests and Experiments, Unit 2

The inspector verified, by a review of Sections 6.1.1.a and 6.9 of

the Techn! cal Specifications, that the licensee has established

.

y

controls for the following:

.'"

>

a.

The handling of requests or proposals for conducting plant

.

tests or experiments involving safety related cornponents,

systems or structures or modes of operation different from

'

those described in the FSAR.

b.

To assure that all tests and experiments will be performed in

accordance with approved written procedures.

c.

To assure that responsibilities have been assigned for review-

ing and approving test and experimental procedures.

d.

To assure that all proposed tests and experiments will be

reviewed to determine whether they are described in the FSAR.

e.

To assure that respensibilites have been assigned to assure

that a written safet/ evaluation pursuant to 10 CFR 50.59,

will be developed for each test or experiment not described in

the FSAR to assure that it does not involve an unreviewed

safety question or enange in the Technical Specifications.

1483 050

.

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.

. mw pp eg

+

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-._

_

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- - . - .

...

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40

13.

Design Changes, Unit 2

Temporary Modifications Lifted Leads and Jumpers

The licensee's procedures were reviewed to verify that controls

have been established for:

a.

The review and approval of temporary modifications in accord-

ance with Section 6 of the Technical Specifications and 10

CFR 50.59.

b.

The use of detailed approved procedures when performing tem-

parary modifications.

c.

The assignment of responsibility for approving procedures in

(b) above.

d.

The maintenance of a formal record of the status of temporary

,

j

modification, lifted leads and jumpers, temporary strainers,

i

and temporary trip points of control equipment.

!

s

(-)

e.

Independent verification where appropriate of installation and

-

removal of temporary modifications, lifted leads and jumpers.

f.

Functional testing of equipment following installation or

removal of temporary modifications,

g.

Periodic review of lifted leads and jumper records.

The following procedures were rev1w d for verification of the

findings above:

AP 1013, Revision 3, Bypass of Safety Functions and Jumper

--

Control.

GP 1003, Revision 2, Control of Design Changes / Modifications.

--

GP 4004, Revision 0, Review of Design Specifications and

--

Requirements.

1483 051

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.

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.

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41

4

14.

Maintenance, Unit 2

i

Housekeeping Controls

The licensee's procedures were reviewed to verify that the follow-

ing housekeeping controls and responsibilities have been established

which include:

a.

Establishment of Housekeeping Zones,

b..

Control of housekeeping during work activities.

Section 2.1 of ANSI N 45.2.3 - 1973 requires the control of house-

keeping during work activities and the establishment of housekeeping

zones.

The licensee's procedures do not address housekeeping zones

or the control of housekeeping during work activities.

The licensee

identified this item under Nonconformance Report (NCR)76-386, and

is currently preparing Station Administration Procedure No.1020

which addresses Housekeeping.

Until the required procedure has

l

been reviewed, approved, and issued, this is an unresolved item

(77-09-03.)

l

. '

.

,

'

'

15.

Surveillance Testing and Calibration, Unit 2

The inspector verified that the licensee has administrative controls

that require:

a.

Calibration requirements for components associated with safety

related systems or functions but which are not specified in

the technical specifications as requiring calibration.

b.

Assignment of responsibility in writing to maintain the " master

calibration schedule" up-to-date.

c.

Performing component calibrations in accordance with approved

procedures which include acceptance criteria.

d.

Assuring that required component calibration schedules are

satisfied.

The following procedures were reviewed for verification of the

findings above:

,

,

'

4

1483 052

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.

42

<

AP 1016, Revision 9. Implementation and Control of Station

--

Maintenance and Modifications.

GP 1003, Revision 2, Control of Design Changes / Modifications.

--

IC. TMI Unit 2 OA Systems List

TMI Unit 1 components, systems, and structures within the scope of

the Met Ed Quality Assurance Plan are listed in the Appendix to

Procedure GP 1008, Revision 1, Quality Assurance Systems List, and

include consumable items such as Boric Acid, Sodium Hydroxide, and

Sodium Thiosulfate.

TMI Unit 2 components, systems, and structures within the scope of

the Met Ed Quality Assurance Plan are currently determined in

'

accordance with Burns and Roe Standard Procedure SP-88.

This list

does not include consumable items such as Boric Acid, Sodium Hydroxide,

etc. The licensee stated that a new QA Systems List for TMI 2 was

under development and would be similar to the TMI 1 list, including

the listing of consumable items.

Until the new QA Systems List for

TMI 2 is approved and issued, this is an unresolved item (77-09-

04.)

-

17.

Preoperational Test Records, Unit 2

a.

Programatic Controls

The licensee has established, through his representatives

GPUSC and UE&C, programatic controls for records created

during the preoperational testing phase.

These records are

controlled as quality assurance records only after they are

completed in accordance with the definition of quality assurance

records as stated in ANSI N 45.2.9, Paragraph 1.4.

Where

applicable, the program defines the controls required by ANSI

N 45.2.9 for the records created during this phase of operations.

Following completion and review, most records a.e turned over

to the licensee so that retention periods are controlled under

the licensee's Quality Assurance Program for Operations rather

than by the Startup and Testing Quality Assurance Program.

The retention /retrievability of records of the Preoperational

Phase is checked by the routine inspections conducted after

issuance of the Operating License.

The inspector iJentified no discrepancies.

1483 053

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43

b.

Records Selected

The inspector selected and reviewed the records listed below

to assure that the programatic controls were used.

The records

were selected to give coverage over a large period of time and

over different stages of record completion and to cover records

of both licensee representative organizations.

Records reviewed

were:

Problem Reports (for Unit 2, numbers started with 2001)

2001 - Decay Heat (BWST) dated July 7,1974

.

--

2050 - Integrated Control System dated June 15, 1976

--

2101 - Integrated Control System dated December 6, 1976

--

2130 - Reactor Protection System dated February 23, 1977

--

Turnover Packages (MTX File)

5.2 - Auxiliary Building Sump Pumps - Electrical

--

,

51.1 - Diesel Generator Air System-Instrument Calibration

--

75.3 - Fire Protection System, Pressure

--

113.3 - OTSG - Chemical Cleaning

--

Preoperational Tests

SP 204/4, Reactor Building Spray Nozzle Air Test dated

--

November 8, 1974

TP 235/5, Circulating Water Pump House dated February 10,

--

1975

TP 235/6, Containment Building Area 3 ump Test dated

--

December 20, 1976

These records were reviewed only for application of program

controls, not for record content / acceptability.

..

1483 054

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-

.

.

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44

,

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l

c.

Observation

,

The inspector observed evidence of a rodent infestation prob-

lem, such as chewed telephone cables, in the areas outside and

under the trailers where records are stored.

Completed records

were stored in fire resistant file cabinets and the inspector

found no evidence of rodent damage on the records reviewed.

The licensee's representative was aware of the problem but

stated that rodents had been limited to areas outside of the

interior of the trailers.

~

The inspector had no further questions at this time.

18. Startup and Test Quality Assurance Program, Unit 2

4

'

The description and controls for this program were reviewed and

,

documented in Report 50-320/76-05. At that time, February 23-25,

1976, audit and inspection activities had not been completed under

the aegis of this program.

Since these activities required review

for acceptability, two followup items (76-05-04 and 76-05-05) were

documented.

These areas were reviewed with results as indicated

()

below.

I

a.

Audits

The licensee's representative, GPUSC, had conducted three

audits during the period from April 1,1976 through January

31, 1977.

During these audits, thirty-one items requiring

followup were identified. The audits reviewed, areas covered,

-

l

and dates conducted are listed below:

76-08, Startup and Test Program Activities, conducted

.

--

April 1 to May 6, 1976;

76-12, Startup and Test Program Organization, conducted

--

June 22-24, 1976; and,

77-01, Jurisdiction and Tagging of Equipment, corducted

--

January 31, 1977.

Apparent gaps in the numbers were filled with audits of con-

struction activities which are conducted by the same group

under the Construction Quality Assurance Program.

Audit 77-01

was issued February 17, 1977, 3 working days prior to this

.

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1483 055

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. _ . .

.-

.

--

..

,

.

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45

inspection, and answers /corre<.tive actions K u e therefore not

available for review. The licensee had identified 23 items,

i

22 which required answers / corrective actions, during the con-

'

I

duct of audits 76-08 and 76-12. The inspector found that 2

of these items, Findings 4 and 8 of Audit 76-12, had not been

'

answered nor had corrective actions been completed as of

February 24, 1977. These items had been identified to the

-

i

audited organizations during the audit conducted June 22-24,

1976 and were officially documented in a letter dated July 12,

1976, which forwarded ccpies of the audit and audit tindings.

j

In answer to the inspector's question, the licensee's represen-

l

tative stated that no measures had been established and docu-

l

mented to assure that conditions adverse to quality identified

during audits would be corrected as soon as practicable.

i

i

'

10 CFR 50, Appendix B, Criterion .iVI states in part: " Measures

shall be established to assure that conditions adverse to

quality.. . . are promptly identified and corrected . . . ."

The accepted Quality Assurance Program for Startup and Testing

(FSAR Section 17.3,) Section 17.3.2, item 3 states in part:

,

( >'-

" ANSI N 45.2 will be complied with . . . ." ANSI N 45.2,

,

Section 17 states in part: " Measures shall be established

i.

-

i

and documented to assure that conditions adverse to quality

h

. . . are promptly identified and corrected as soon as prac-

ticabl e . . . ."

The failure to establish and document measures to assure that

.

conditions adverse to quality will be corrected and the failure

l

to correct 2 of the 22 conditions requiring corrections as

l

soon as practicable collectively constitutes an Infraction

level Item of Noncompliance (77-09-01.)

'

l

Followup Item 76-05-05 is closed.

b.

Inspections

The licensee's representatives, GPUSC and UE&C, had conducted

inspections of activities under the Startup and Testing QA

Program since the previous inspection.

A sample of these

inspection reports were reviewed.

The reports reviewed,

area (s) covered, and dates conducted are listed below:

14831056

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. . . _ . . . , _ . . _ . _ _ _

.

. . _ _ _ _ . _ . _ . _ _

_ _ . _ . . . _ _ . ,

_ _ _ . , _ ,

._

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. -_.

--.

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. - -

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46

'

l

P-3307, Electrical Circuits, January 12, 1977

--

P-3143, Punch List Items, July 8, 1976

--

P-3336, Electrical Circuits, February 18, 1977

--

P-3335, Flange Studs, February 17, 1977

--

P-3290, Terminations, December 30, 1976

l

--

l

P-3291, Terminations, January 3, 1977

--

'

P-3088, Rectifier EEJ-2-2a, February 24, 1976

--

P-3162, Rectifier EEJ-2-2a, August 17, 1976

--

P-3331, Main Steam Punchlist, February 7,1977

--

'

P-3343, Main Steam Hydro, February 21, 1977

--

P-3344, OTSG Hydro, February 21, 1977

--

.

!

The inspector selected approximately 10% of the issued reports

!

for review to assure that documentation, followup, and close-

out controls specified in the licensee's program were carried

out.

,

The inspector identified no discrepancies.

'

Followup Item 76-05-04 is closed.

19.

Unit 1/ Unit 2 Interface Ite_m

During discussions with plant personnel, the inspector learned

,

that extraction steam from the Unit I turbine had been exported to

Unit 2 to allow preoperational testing of its secondary systems.

Based on further discussions with plant personnel and review of

procedures, the inspector determined that the steam had been

exported and the condensate returned in accordance with approved

Unit 1 procedures.

Additionally, the Unit 1 Emergency Procedure

for responding to Steam Generator tube leakage had been revised to

1.483.057

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