ML19276H296

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Insp Rept 50-289/72-05 on 720320-22.Deficiencies Noted: Procedures for Loss of Instrument Air Contain No Provisions for Signatures of Approving Personnel & Documents Do Not Provide for Licensee Response to Actions
ML19276H296
Person / Time
Site: Crane Constellation icon.png
Issue date: 05/03/1972
From: Brunner E, Mcleod B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19276H275 List:
References
50-289-72-05, 50-289-72-5, NUDOCS 7910160640
Download: ML19276H296 (9)


See also: IR 05000289/1972005

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S'. ATOMIC ENERGY C0'O!ISSION

DIVISION OF COMPLIANCE

REGION I

CO Inspection Report No. 50-289/72- 05

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Subject: lietronolitan Edison Company

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Three Mile Island 1

License No. CPPR-40

Location: Middletown, Pennsv1vania

Priority

Category

B

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Type of Licensee: Power Reactor (PJR)

Type of Inspection: Routine, Unannounced

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Dates of Inspection: March 20-22

1972

Dates of Previous Inspection: March 8 & 9, 1972

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Principal Inspector:

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B.'K. McLeod, Reactor Inspector

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Accompanying Inspectors: none

Date

Date

Other Accompanying Personnel: None

Date

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Reviewed By:

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E. J Brunner, Senior Reactor Inspector

Proprietary Information:

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7910160

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Section I

G

Enforcement Action

None

Licensee Action on Previously Identified Enforcement Matters

No enforcement items were identified in the previous Startup and Testing

Program Inspection Report.

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Unresolved Items

None

Status of Previously Reported Unresolved Items

No unresolved items were identified in the previous Startup and Testing

Program Inspection Report.

Unusual Occurrences

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None

Persons Contacted

Metropolitan Edison Company

J. L. Wise, Station Superintendent

J. Colitz, Supervisor of Operations

R. W. Zechman, Training Coordinator

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General Public Utilities Service Company

J. J. Barton, Startup and Test Manager

T. W. Hawkins, Startup Engineer

Burns & Roe, Inc

N. E. Dickinson

Management Interviev

On March 21, 1972, a management interview was held with Mr. J. J. Barton.

The following items were discussed:

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Administrative Controls and Quality Assurance for the Test and Startuo

Program

The inspector stated that no items of nonconformance or noncompliance

were observed.

He expressed concern about the schedule for development

of the Quality Assurance Program and Administrative Controls, relative

to the test schedule.

Mr. Barton stated that maximum eff6rt is being

expended to get these programs developed as rapidly as possible.

(Paragraphs 7 & 8)

On March 22, 1972, a management interview was held with Mr. J. L. Wise.

The following items were discussed:

On-Site Training Procram

The inspector stated that no items of noncompliance or nonconformance were

observed. He indicated that the lack of admini erative controls for the

On-Site Training Program, while not a citeable item due to the fact that

this program was almost entirely complete prior to the effective date of

Appendix B to 10 CFR 50, was a cause for concern.

He further stated that

any subsequent training program must be conducted in accordance with the

requirements of 10 CFR 50, Appendix B.

(Paragraph 10)

Station Operating Procedures

The inspector stated that no items of nonconformance or noncompliance were

cbserved. He indicated that the C0 review of the Station Operating Pro-

cedures Program would continue and any deficiencies noted would be brought

to the licensee's attention for resolution.

Paragraph 5)

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Section II

Additional Subjects Inspected. Not

Deficiencies Or Unresolved Items Were FoundIdentified In Section I, Where Nr

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1.

General

The licensee (Mr. Barton) provided the following information

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target dates for major plant milestones ~:

regarding

Commence Preoperational Testing - 5/72

Ready for Core Loading - 3/73

Ready for 20% power - 5/73

Ready for 100% power - 7/73

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2.

Use of Membranes in Water Stora2e Tanks

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The inspector inquired if Three Mile Island had any membranes i

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water storage tanks.

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the condensate storage tanks.Mr. Wise stated that there are membranes in

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He also stated that there are no

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membranes installed in any other water storage tanks.

inquired as to what surveillance program is planned to monit

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The inspector

condition of these membranes.

or the

in time plans for equipment surveillance had not bMr. Wise indicated

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inspector stated that he would raise this question again at

een developed.

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a later date.

3.

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On-Site Trainine Program

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of the on-site training program:The following items war

a.

,

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on

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classes cove ed h p riod o 10-20-69 to 9-1 -

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am.

These

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of examinations covering the period of

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10-20-69 to

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(3)

Examination grade r'ecords for the period of

9-18-70.

10-20-69 to

(4)

Reactor physics examinations dated 4-3-70 and 4-17-70

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(5)

Nuclear instrumentation examination dated 8-21-70.

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4.

Administrative Controls for the Test and Startuo Program

a.

Personnel

Mr. Barton stated that Mr. Baker, previously the Test Superintendent,

had resigned and had not yet been replaced.

In the interim, Mr. Earton

stated that he is filling in for Mr. Baker and that GPU has contracted

with Burns 6 Roe to have N. E. Dickinson assigned to the Three Mile

Island S ::e to prepare the documents governing,the conduct of the

test program.

b.

Documentation

The inspector reviewed the following partially complete draft documents:

(1) Three Mile Island - 1 Test Manual

The master administrative control document which will be used

to control the TMI-l Test Program.

(2) Three Mile Island -1 Master Test Index (Format outline)

This document will list each system, the testing to be done on

that system, and the documents controlling each test.

(3) Test Procedure (Format outline)

This document will specify what items must be tested during the

individual test and will be used by the author of the individual

test procedure to guide him in preparation of that document.

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(4)

Individual Test Procedure (Format outline)

This will be the procedure for the step by step conduct of each

test.

(5) Test Instruction (Format outline)

This will define the administrative controls particular to an

individual test.

Details of Subjects Discussed in Section I

5.

Station Ooeratine Procedures

a.

General

The licensee does not presently have any operating procedures in final

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form nor is the procedure index complete; however, draft procedures

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were available in some catergories.

The inspector reviewed the following

draft procedures:

(1)

Emergency Procedure - 1202-36, Loss of Instrument Air

(2) Auxiliary System Operating Procedure 1104-11, Nuclear Service c

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closed cooling water system.

(3) Auxiliary system operating procedure 11044 2, Decay Heat River

Water System.

The inspector reviewed his findings with Messrs. Colitz and Wise.

The deficiencies identified and the licensee's response to these

items were as follows:

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b.

EP 1202-36 Loss of Instrument Air

.(1) Deficiency - The procedure contains no provision for signatures

of the persons approving the procedure.

Licensee Content - Mr. Wise stated that final draf ts of all

procedures will contain signatures of the persons approving

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the procedure.

(2) Deficiency - The procedure contains no recuirement that the

operator verify that automatic actions have taken place and

to manually initiate any action that fail to function

automatically.

Licensee Ccmment - Mr. Wise stated that the emergency procedure

format will be modified to include this item.

(3) Deficiency - The procedure does not identify the plant response

to the failure.

Such information as the direction and probable

magnitude of major paramater changes should be included in

brief form.

Licensee Comment - Mr. Wise stated that consideration would be

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to include

given to modifying the emergency procedure format

this information.

(4) Deficiency - This procedure does not cover the total loss of

instrument air situation.

The procedure assumes that instrument

air pressure decreases slowly and that specified corrective

actions return system pressure to normal.

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Inspector's Ccement - The inspector stated that a total and abrupt

loss of instrument air pressure is a realistic occurrance and that

this procedure should cover that possibility.

Licensee Comment - Mr. Wise stated that the procedure will be

modified to cover this possibility,

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c.

OP 1104-32 - Decav Heat River Water System

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Deficiency - This procedure does not have provisions for including

limits imposed by Technical Specifications.

Licensee Comment - Mr. Wisa stated that operating procecures will

include appropriate Technical Specifications limits.

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d.

OP 1104-11 - Nuclear Service Closed Cooling Water System

Deficiency - Item 14.2.2.2, which deals with water quali y for

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Nuclear Service closed cooling water system, references a GAI

specification which may not be readily available for operating

personnel.

Inspector's Comment - The inspector stated that if this information

is important it should be in the procedure; if not, it should be

eliminated.

Licensee Comment - Mr. Wise stated that this reference will be

eliminated from the procedure since all water quality require-

ments will be in the plant water chemistry procedures.

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6.

Preoperational Test Program

The inspector reviewed an index of preoperational tests entitled:

Test Procedure List - Three Mile Island - Unit 1.

The insp2ctor discussed the results of this review with Messrs. Barton and

Digkinson.

The deficiencies noted and the licensee's response were as

rollows:

Deficiency - It was not apparent that the licensee planned to conduct

the following pre-operational tests:

Solid Waste Disposal System

Charcoal and Particulate Filter Tests

Plant Response to Loss of Instrument Air

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Licensee Coment - Mr. Barton stated that these tests will be conducted.

7.

Administrative Controls for the Test and Startup Program

The inspector inquired as to the status of development of the Administra-

tive Controls for the test program. Messrs. Barton and Dickinson

indicated that work on these was in progress and that the bulk of these

controls would be in place by the start of preoperational testing in

May, 1972. The inspector stated that it was his positien that the

Administrative Controls required to assure adequate testing of components

and systems must be instituted prior to commencement of preoperational

testing.

He indicated that this area was of particular concern

to CO and that he would follow it closely.

He further stated that failure 1

have adequate Administrative Controls would most certainly result in

appropriate enforcement action being initiated.

8.

Quality Assurance for the Test and Startun Progren

The inspector inquired as to the status of development of the licensees QA

Mr. Barton

Program covering the preoperational and startup testing phases.

indicated that a Quality Assurance Program designed to comply with Appendiz

B to 10 CFR 50 is in the development stage.

Mr. Barton also stated that the

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QA Program should be ready in June or July.

He indicated that while this d4

not coincide with the scheduled date for commencement of preoperational

testing, any further slippage in the construction schedule will move back

the preoperational testing dates and allow the QA Program to be functional

when testing is commenced. The inspector stated that it was his position

that the entire testing program must be covered by a functioning QA

Program and that failure to have the program in place at a time consistent

with the schedule for performing the activities would be a violation of

Criterion II of Appendix B to 10 CFR 50.

Mr. Barton indicated that he was

aware of the inspectors position on this matter.

9.

Post Erection Flushing

The inspector inquired as to the status of development of post erection

flushing procedures.

Mr. Barton stated that none were yet in final form.

Mr. Barton described plans for post erection flushing procedures as follows:

Generic procedures for the different types of flushfr.g will be written

and approved by the Test Working Group (TWG).

From these generic

procedures individual flush procedures will be written and used in

conjunction with marked up flow diagrams to control the conduct of

the individual tests. These will not be approved by the TWG but

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rather by representatives of GAI, B&W, UE&C and GPU.

The inspector reviewed a draft Individual Flush Procedure for the Decay

Heat Closed Cycle Cooling Water System.

The inspector noted that the

acceptance criteria did not define the flow velocity required to produce

After discussion with the inspector, Mr. Barton agreed

an adequate flush.

that minimum flow velocities would be defined in flush procedures for

major piping runs.

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10. On-Site Trainina Program

The inspector stated that he wished to review the Administrative Centrols

He stated that he was specifically

for the Operator Training Program.

interested in documentation which defines:

Responsibilities for the preparation and conduct of training lectures

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Responsibilities and guidelines for the evaluation of training

effectiveness

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Record requirements

Mr. Zechman stated that there were no administrative control documents

for the Operator Training

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