ML19276H321
| ML19276H321 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/19/1973 |
| From: | Davis A, Rebelowski T, Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19276H310 | List: |
| References | |
| 50-289-73-22, NUDOCS 7910160663 | |
| Download: ML19276H321 (14) | |
See also: IR 05000289/1973022
Text
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U. S. ATO.lIC ENERCY CRI:!ISSIO:3
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DIRECTORATE OF REGULATORY OPERATIO S
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REGION I
R0 Inspecticn Report !!o. :
50-289/73-22
Docket 1:o. :50-259
License No. : CPPR '
Licensce:
Metropolitan Edison Company
Three Mile Island - Unit 1
Priority:
B.1
Category:
Location:
Middletown, Pennsylvania
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Type of Licensee:
"'I"*' ^"" "PC8"
Type of Inspection:
November 14-16, 1973
Dates of Inspection:
October 29-31, 1973
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Dates of Previous Inspection:.
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Reporting Inspector:
fv2.L.Spessard,ReactorInspector
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Accompanying Inspectors:
n
Date
[rrT. A. Rebelowski, Reactor Inspector
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Date
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'Other Accompanying Personnel:
NoNy
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Reviewed by:
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A. B. Davis, Senior Reactor Inspector, React'or Operations Branch DU L
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SUMMARY OF FINDINGS
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Enforcement Action
A.
Violations
.
None Identified
B.
Safe ty Items
None Identified
Licensee Action on Previousiv Identified Enforcement Items
A.
None required relative to test and startup activities
Unusual Occurrences
None
,
Other Sienificant Findines
A.
Current
1.
The initial startup testing program, while consistent with the
FSAR, does not includ.e the part-length rod effectiveness test
at 757. power, as set forth in Regulatory Guide 1.68 Preoperational
and Initial Startup Test Programs For Water-Cooled Power
Reactors. This item remains unresolved pending review by
R0 Headquarters. (Paragraph 3h)
2.
Site activities remain on schedule relative to commencement of
Hot Functional Testing on December 19, 1973.
B.
Status of Previousiv Reported Unresolved Items
1.
Criterion X, Appendix B,10 CFR 50 (R0 Inspection Report No.
50-289/73-10). Item is resolved based on revision of the Quality
Assurance Plan.
The Three Mile Island Quality Assurance
Program for Startup and Test Activities is consistent with
Appendix B to 10 CFR 50. (Paragraph 3a)
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2.
PORC Quorum (R0 Inspection Report No. 50-289/73-06).
Item
is resolved based on amendment of the FSAR. (Paragraph 3c)
3.
No change in other item.
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Management iiterview
An exit interview eas conducted on November 16, 1973 at the conclusion
of the inspection.
Items discussed and personnel in attendance were
as follows:
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Licens~ee Reoresentatives
J. Herhein, Assistant Station Superintendent, Met Ed
G. Miller, Test Superintendent, CPUSC
M. Stromberg, Site Auditor, GPUSC
T. Sturgeon, QA Specialist, GPUSC
RO:I Reoresentatives
L. Spessard
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T. Rebelowski
A.
Preoperational Procedures
Inspection findings relative to the review of test procedures, test
procedure history files, test results, and previously reported test
procedure deficiencies were discussed. (Paragraph 2)
B.
Preoperational and Initial Startuo Test Program
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Inspection findings relative to the reviri of Revision 2 to the
QA Plan for Startup and Test, the Test Manual and Section 13 of
the FSAR, Plant Operations Review Committee, Test Instructions,
Hot Functional Testing, ECCS Testing, Control Rod Drop Time
Measurements, Initial Startup Tests, and Emergency Procedures
were discussed.
Additionally, licensee commitments received
during the inspection relative to these matters , as appropriate,
were discussed, and these commitments were acknowledged by the
license'e representatives. (Paragraph 3)
C.
Surveillance Testing Program
Inspection findings relative to this matter were discussed. (Paragraph
4)
D.
Met Ed Instrument Shoo
Inspection findings and licensee consittents received during the
inspection relative to this matter were discussed, and the commitments
were acknowledged by the licensee representatives. (Paragraph 5)
E.
Flood Control Emergency Procedure
Inspection findings and licensee commitments received during the
inspection relative to the review of this procedure were discussed,
and the commitments were acknowledged by the licensee representatives.
(Paragraph 6)
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Persons Contacte
Metropolitan Edison Company
J. Eerbein, Assistant Station Superintendent
J. Colitz, Station Engineer
R. Miller, Tes t Coordinator
D. Shovlin, Maintenance Supervisor
D. Barry, Instrument Shop Supervisor
General Public Utilities Service Corooration
J. Barton, Startup and Test Manager
G. Miller, Test Superintendent
R. Toole, Assistant Test Superintendent
M. Nelson, Technical Engineer
R. Claussen, Lead Engineer-Instrument and Controls
R. Brownewell, Cognizant Engineer
W. Behrle, HFT and PET Program Coordinator
T. Faulkner, Senior Test Planner
J. Wright, Quality Assurance Manager
,
M. Stromberg, Site Auditor
T. Sturgeon, Quality Assurance S ecialis t
P
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2.
Preoperational Test Procedures
a.
Status of Test Procedure Preparation, Review, and Anoroval
~
Preoperational Test Procedures Approved for Performance
73%
Precperational Test Procedures Awaiting Final Approval
1%
Preoperational Test Procedures Under Review by TWG & DOT
10%
Preoperational Test Procedures. Written and Undergoing
10%
In-house Review
Preoperational Test Procedures Not Started
6%
The licensee's target date for completion is the week of December 10,
1973. A review of the licensee's procedure status and schedule
indicates this target date should be met.
b.
Status of Precuerational Testing
Preoperational Tests Completed and Accepted
18%
Preoperational Tests Completed and Under Review
8%
Preoperational Tests in Progress
18%
Preoperational Tests Not Started
56%
c.
RO:I Review of Preonerational Test Procedures
(1)
TP 153/3 Fluid Block System Functional Test
The inspector and licensee representatives dicussed and
resolved questions on individual fluid block failure logic
and actuation, me-kod of determining leakage criteria,
limitations and precautions , alarm actuation, and testing
a single failure of redundant positioning solenoids
during functional testing.
One deficiency was identified
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with respect to the method of obtaining reference levels
for the Fluid Block Storage Tanks during the test, and
this deficiency was corrected by a written exception to
the procedure in accordance with Test Instruction No.18.
RO:I has no further questions on this procedure at this
time.
(2)
TP 153/4 Fluid 31ock System Actuation *f me Determination
The inspector and licensee representatives discussed and
resolved minor typographical errors in the areas of test
sequencing and data recording.
RO:I has no further
questions on this procedure at this time.
d.
RO:I Review of Preocerational Test Procedure Historv Files
The inspector reviewed the history file for each of the following
preoperational test procedures:
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TP 600/3 Soluble Poison Concentration Control
TP 600/20 Loss of Electrical Power Test (Without E.S.)
TP 600/11 Emergency Feed System and OTSG Level Control Test
TP 200/ llc Reactor Coolant Pu=p Flow Test Part C-Hot, No Core
Ihese procedures were . approved for performance by the Test
Working Group (TWG) during their meeting (No. 72) which was
conducted on November 14, 1973 and which was attended by the
inspecto r.
The inspector found documentation that indicated
the requirements of Test Instru.ction No.18 Test Procedure
Documents had been implemented for these procedures.
e.
R<0:I Review of Preonerational Test Results
The inspector reviewed the completed test package as accepted
by the licensee and is satisfied with the documentation of
performance and results of the following test:
TP 203/1 Decay Heat Renoval System, BWST Functional Test
The system for review and approval of test results was discussed
with cognizant licensee representatives, and the inspector
expressed his concern at the apparent slowness of the system
in view of the fact that several tests , which had been conducted,
had not been processed through the review and approval circuit.
The licensee representatives indicated their awareness of this
situation, and the inspector was informed that the system was
under re/iew. Methods for improving the system wer
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f.
RO:I Review of Previousiv Reported Test Procedure Deficiencies
(1)
TP 154/3 Penetration Pressurization Operational Test
This procedure was approved for performance by the TWG
on November 8, 1973.
The two deficiencies, as identified
in RO Inspection Report No. 50-289/73-11, Paragraphs 2.c.(5)
(a) and (b), have been corrected by inclusion of additional
information in the procedure.
RO:I has no further comments
on this procedure at f.his time.
3.
Preoperational and Initial Startup Test Program
a.
QA Plan for Startuo and Test
Revision 2 to the QA Plan for Startup and Test Three Mile Island
Nuclear Station - Units 1 and 2 was approved by the Manager of
Quality Assurance and the TMI Project >bnager on November 12,
,
1973.
This revision included a requirement in Section X of
the Plan for auditing preoperational and startup tests by the
TMI Site QA Organization as discussed in Section XVIII of the
Plan.
The previous RO:I finding relative to this matter is
res olve d . *
b.
Test Manual and FSAR (Section 13)
Revision 2 to the Test Manual was approved by the TWG on October 23,
1913 and received corporate management concurrence on October 29,
1973.
The inspector reviewed the administrative controls for
the tcst program, as described in the Test Manual, Revision 2,
with respect to the statements contained in Section 13 of the
FSAR, which had been recently revised by Amendment No. 43 dated
November 1, 1973.
The inconsistencies between the Test Manual
and the FSAR, which had been identified during a previous R0
inspection, are resolved.**
As a result of this review, the inspector informed the licensee
representative that the safety related tests to be performed during
the preoperational and initial startup test phases, as described
in Tables 13-2,13-3, and 13-4 of the FSAR (Amendment No. 43),
did no,t include several tests which were previously described
in Tables 13-1 and 13-2 of the FSAR (Amendment No. 26) and
which are included in the Fbster Test Index (MTX) .
The
specific tests which were not included in these tables were
discussed with the licensee representatives. These
tests affect the following systems :
R0 Inspection Report No. 50-289/73-10, Paragraph 2.b
- R0 Inspection Report No. 50-289/72-17, Paragraph 3.e
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(1)
Core Flood
(2) Decay Heat River Water
(3)
Fire Protection
(4)
Gaseous Waste Disposal
(5)
Intermediate Cooling
(6)
Liquid Waste Disposal
(7)
Reactor Building Purge
(8)
Post Accident Purge
(9)
Reactor Protection
(10) Spent Fuel Cooling
(11) Solid Waste Disposal
(12) Main and Auxiliary Steam
(13) Feed Water
(14) Area Radiation Monitors
Additionally, the inspector discussed several inconsistencies
relative to Test No. or Title, as described in Table 13-2, with
respect to the testing described in the MIX. These included:
TP 330/1, TP 301/4, TP 360/1A, TP 360/lB, TP 360/lc, TP 160/3,
TP 160/4, TP 235/1 and TP 175/2 (As described in Table 13-2).
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A licensee representative stated that Tables 13-2, 13-3, and 13-4
would be reviewed and then revised by FSAR amendment to be
consistent with the testing program described in the MTX. The
inspector stated that he had no further questions on this matter
at this time.
c.
Plant Ooerations Review Committee (PORC)
The Test Manual requires that the PORC review safety related
test procedures and that this review be coordinated through
the Station Superintendent's TWG representative. During a
previous R0 inspection *, it was determined that this requirement
was being met; however, it was also observed that the PORC did
not always have a quorum, as specifiad in the FSAR (Chairman
plus three members), and the licensee indicated this matter
would be resolved by acending the FSAR.
By Amendment No. 42
dated October 1,1973 to the FSAR the licersee revised the
PORC quorum (Section 15.6.1.I.l.c.) to be three members , including
the Chairman or Vice Chairman.
A review of PORC meeting
minutes during the previously referenced R0 inspection, a
subsequent RO inspection **, and this RO inspection (thetings
No. 198-201 for the period October 18-November -3,1973)
disclosed that a quorum, as currently specified in the
FSAR, had been present at each meeting.
This matter is
resolved.
d.
Test Instructions
' The inspector reviewed the following recently revised Test
1j]} }4[
Ins tructions :
R0 Inspection Report No. 50-289/73-06, Paragraph 4.b
R0 Inspection Report No. 50-289/73-18, Paragraph 2.e
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TI-3
Briefing and Dry Run (Revision 3, dated November 8,1973)
TI-7
GPU Startup Problem Report (Revision 4, dated October 1, 1973)
TI-8
Unusual Occurrences (Revision 1, dated October 10, 1973)
TI-17 Shift Test Engineer's Log (Revision 1, dated October 17, 1973)
Revisions to these TI's were made in accordance with the Test
Manual, and the revisions clarified program requirements.
Revisions
to TI-3 pertained to issuance of a Test Manning Assignment
Document and attendance of briefings when this docu=ent is in
effect.
The previous RO:I finding relative to TI-3 is resolved *
e.
Hot Functional Testing (HFT)
The licensee's program relative to HFT, which is scheduled to
begin on December 19, 1973, was discussed with cognizant GPU
Startup personnel.
According to the schedule of events leading
to HFT, the December 19, 1973 date appears realistic, and the
,
controlling item is the completion of the insulation requirements
for the following systems : Reactor Coolant , Makeup, Core
Flood, Decay Heat, Emergency Feed Water, Main Steam and Feed
Water. The following documents , which were in preparation,
will be used to control HFT:
(1)
TP 600/28 Controlling Procedure for HFT
(2) Master Test Schedule for HFT
(3)
Prerequisite List for HFT
(4)- Test Manning Assignment Document
The Prerequisite List for HFT was agreed to by thc TWG during
their meeting (No. 72) which was conducted on November 14, 1973
and a smooth copy was scheduled for submittal within a week.
This document included requirements for controlling combustibles
in the Reactor Building in accordance with the licensee's
previous commitment **.
The licensee's program relative to pipe
hangers and restraints was discussed, and a licensee representative
stated that the details of this program would be provided during
a future RO inspection.
The licensee representative stated that
- RO Inspection Report No. 50-289/73-20, Management Interview Item A.
- RO Inspection Report No. 50-289/73-18, Management Interview Item B.
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verification of the hanger program to support HrT would be
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included in the Prerequisite List for HFT. Matters relative
to HFT will be reviewed during subsequent R0 inspections.
f.
ECCS Testing Program
The licensee's proposed ECCS testing program was reviewed with
cognizant GPU Startup personnel, and RO's minimum acceptable
requirements relative to this matter were discussed. As a
result, the following commitments were received from these
representatives :
,
(1)
Test procedures involving these systems will include flow
balance criteria.
(2)
The H.P. Injection check valves will be tested for
operability at normal reactor coolant system operating
conditions, if B & W doesn't object.
(3)
The Core Flood check valves will b,3 tested for operability
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at normal reactor coolant system operating conditions , and
this test will be included in TP 600/28 Controlling
Procedure For HFT.
(4)
Criteria for determining acceptability of system piping
movements and adequacy of supports under system startup
conditions and steady state operation will be included in
TP 600/21 Integrated E.S. Actuation Test.
RO:I has not further questions on this matter at this time.
g.
Control Rod Drop Time Measurements
The licensee's proposed test relative to this subject was
reviewed with cognizant GPU Startup personnel, and R0's minimum
acceptable requirements relative to this test were discussed.
As a result, the following commitment was received from these
representatives:
(1)
TP 330/5 CRD Trip Test will include tl.e following drop time
measurements : Each rod, cold and hot, at rated recirculation
flow and with no recirculation flow plus ten additional
measurements for each of the fastest and slowest rods.
RO:I has no further questions on this matter at this time.
14lh
34h
h.
Initial Startuo Tests
The licensee's proposed program relative to this subject was
reviewed with cognizant GPU Startup personnel, and RO's
minimum acceptable requirements relative to this matter
were discussed.
As a result, the following commitments and/or
statements were received from these representatives:
(1)
TP 500/3
~hemical and Radiochemical Ana?
is will be
performec -mt each tes t plateau.
(2)
TP 800/35 Effluent Monitoring will be performed at each
test plateau.
(3)
TP 800/3 Biological Shield Survey will be performed at
test plateaus of 40% and 100% power.
(4)
TP 800/11 Core Power Distribution, which will be conducted
at each test plateau, will include the Process Computer
for comparison of safety related predicted values with
measured values.
(5) A test for Part-length rod insertion and removal to
determine their effectiveness in controlling a zenon
transient at 75% power is not included in the program.
This test will bc performed at Oconee 2, and the results
of that test will be used by GPUSC as the basis for
not performing the test.
With the exception of item (5) R0;I has no further questions on
,
this matter at this time .
Item (5) is an unresolved item and
will be forwarded to R0 Headquarters for resolution.
1.
Emergency Procedures
According to Section 13.1.5 of the FSAR (Amendment No. 43),
selected emergency ope' rating procedures will be performed
during the test program, and those emergency procedures which
are not possible to perform will be dry-run by the station
s ta ff .
This matter was discussed with cognizant licensee
representatives, and the inspector was informed that the
program to accomplish this requirement had not been finalized.
The licensee's proposed program was discussed with the
representatives, and the inspector stated that he would
expect the program to identify each emergency procedure,
to define method of testing (actual or dry-run) each
procedure, and to describe when, with respect to the
test program, each procedure will be tested.
This matter
will be reviewed during a subsequent R0 inspection.1 } } }
} } Q
4.
Surveillance Testing Program
During a previous RO inspection *, the licensee was a'dvised of RO:I's
position relative to documentation and implementation of a program
for conducting all surveillance tests required by the Technical
Specifications prior to issuance of an operating licensee.
During
this R0 inspection, the licensee's proposed program for
accomplishing surveillance testing requirements was discussed with
cognizant licensee representatives, and the following information
was obtained:
- RO Inspection Report No. 50-289/73-04, Management Interview, Item D
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a.
Administrati'
Procedure 1010 Surveillance T
Program, which
establishes administrative controls for performance and
documentation of the total surveillance test program described
in the Technical Specifications, is approved.
b.
The licensee has determined that 123 surveillance test procedures
are required.
83% of these procedures are written, and 41% of
these procedures are approved.
c.
Station battery surveillance (weekly and monthly) and
environmental monitor surveillance (quarterly) are being
performed.
d.
The licensee's system for integrating the surveillance testing
program into the preoperational and initial startup testing
program has not been finalized.
Regarding this matter, the
inspector stated that he would expect the system to provide
the following details :
(1)
Identify each test that can be performed prior to core
loading, describe how each test will be accomplished (by
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TP or Surveillance Procedure-), and define when, with
respect to the preoperational test program, e ach test
will be perforued, thus establishing the base date for
the required testing frequency.
(2)
Identify each of the remaining tests that will be performed
after core loading, describe how each test will be acco=plished
(by TP or Surveillance Procedure), and define when, with
respect to the initial startup test program, each test
. will be performed, thus establishing the base date for
the required testing frequency.
This area will be reviewed during subsequent RO inspections .
5.
Met Ed Instrument Shop
The inspector reviewed Met Ed's method of controlling instrument
calibration.
For this review the inspector selected 3 gauges not
covered by Technical Specification surveillance requirements as
a sampling check, and the following observations were made:
a.
Retrieval of calibration data was not accomplished in a timely
manner,because the gauge nomenclature did not appear on the
P&ID's.
A licensee representative had to identify the system
each gauge was cataloged or filed uadet.
Once the system was
identified, the calibration data was provided.
The licensee
representative indicated a recheck of gauge nemenclature would
be made to provide consistency with the P&ID's,
b.
A uniform method of determining gauge in-calibration period was
lacking because the licensee had not established standards for
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the program.
The licensee representative indicated that this
matter was being reviewed and that standards would .e developed
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for calibrating gauges at specified periods.
c.
Alcohol and water were being used to clean gauges ; however,
other acceptable cleaning #1uids that may be required had not
been defined.
The licensee representative indicated this
matter would be reviewed and that other acceptable cleaning
fluids would be defined, as required.
RO:I has no further questions on items a and e at this time.
Iten
b will be reviewed during subsequent RO inspections .
The inspector reviewed Met Ed's control of test equipment to determine
the implementation of TI-19 Control
" Test Equipment.
The
inspector's observations and discussions revealed the following:
a.
Although personnel have been instructed to comply with the
requirements of TI-19, all of the personnel had not read
TI-19.
A licensee representative indicated personnel
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would be required to read TI-19 ahd this would be documented.
b.
Calibration labels and cleanliness control tags were available
in the instrument shop.
c.
Test gauges were marked and segregated as to use (air, water,
and oil).
.
d.
Equipment for cleaning of gauges is still on order.
These items had been reviewed during a previous RO inspection *.
RO:I
has no further questions on items b and c at this time.
Items
a and d will be reviewed during a subsequent R0 inspection.
6.
Flood Control Emereency Procedure No. 1202-32 (Revision 1, November 3,
1973)
The inspector conducted a review of this procedure, which had been
reviewed by the PORC and approved by the Assistant Station Superintendent.
During this review, the inspector identified a nudber of apparent
deficiencies which required resolution.
The deficiencies identified
and the licensee representatives comments were as follows:
a.
Deficiency - In paragraph 3.2.2 floor drains and sump pumps are
checked to ensure proper operation; however, the
specific drains and sump pu=ps are not identified.
Licensee Comment - This matter will be corrected by use of a check-off
list.
-Inparagraph3.2.3theplantisplacedinbe 01
b.
Deficiency
shutdown condition if significant deterioration
of the dikes is discovered and the river flow is
IRO Inspection Report No. 50-289/73-15, Paragraph 6.b.
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greater than 340,000 cfs ; however,' udder these
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conditions a SHUTDOWN order by the Station
,
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Superintendent is required, i.e. , the station
is placed into a cold shutdown condition as soon
as possible.
Licensee Comment - The procedure will be revised to require a
SHUTDOWN order be given under these conditions.
Additionally, significant deterioration of the
dikes is deemed to mean that the design
function has been or may be componised.
c.
Deficiency - In paragraph 3.2.4 the area in the vicinity of the
North Bridge will be periodically inspected for
buildup of debris; however, the word periodically
does not provide adequate definition as to when
these inspections will be made.
Licensee Comment - The word periodically is deemed to mean at
least daily and at more frequent intervals
.
depending on flood conditions, as judged
necessary by the Station Superintendent.
The procedure will be revised to reflect this
intent.
d.
Deficiency - In paragraph 3..
' s 7 astic sheeting and sand bags
are to be made a n ; 'able to help minimize inleakage
to buildings if necessary; however, control of this
material is not defined, and the specific location
and conditions as to where and when the material
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will be used are n.ot identified.
Licensee Comment - The procedure will be revised to provide
definitive requirements regarding this matter.
e.
Deficiencv - In paragraph 3.2.6 periodic soundings in front of
the intake structure are to be accomplished to detect
sediment accumulation; however, the word periodic
does not provide adequate definition as to when
these soundings will be made, baseline sediment
accumulation is not defined, and a limit relative
to sediment accumulation and actions required as
the limit is approached and reached are noe defined.
.
141 jas} 53
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Licensee Comment - The word periodic is deemed to mean at
daily and at more frequent intervals depending
on data evaluation, as judged necessary by the
Station Superintendent.
The procedure will
be revised to reflect this intent. Baseline
sediment accumulation will be determined and
included in the procedure.
A limit for sediment
accumulation will be defined and included in
the procedure; actions required as this limit
is approached and reached will be included in
the procedure.
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e
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Licensee resolution of the above deficiencies, as indicated by
their comments, will be verified during a subsequent R0 inspection.
As a part of this procedure review, the inspector telephoned the
Federal-State River Forecast Center in Harrisburg, Pennsylvania
using one of the telephone numbers listed in paragraph 1.2 to
verify that the notification arrangements contained in paragraph
2.1 had oeen implemented. During this telephone conversion, the
inspec';or was provided the current river flow rate and the river
flow rate at which the Three Mile Island Station would be notified
by the Forecast Center.
The inspector is satisfied that the
arrangements are implemented.
Additionally, Appendix II provides
a correlation between river stage (feet above sea level) and river
flow (cfs), and the inspector questioned the licensee representative
as * 1 whether river stage had been marked off at the River Water
Intake Structure so that the river flow corresponding to the various
,
action levels contained in the procedure was readily identifiable.
The representatives indicated that the river stage corresponding to
each action level in the procedure was not marked off at the River
Water Intake structure, but that this would be accomplished. This
matter will be reviewed during a subsequent R0 inspection.
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