ML20040G097

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IE Insp Rept 50-289/81-32 on 811117-820108.Noncompliance Noted:Floor Pipe Penetration within 40 Ft of Welding Operation Not Covered
ML20040G097
Person / Time
Site: Crane 
Issue date: 01/22/1982
From: Chung J, Fasano A, Haverkamp D, Young F
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20040G093 List:
References
50-289-81-32, IEB-80-24, IEB-81-01, IEB-81-02, IEB-81-1, IEB-81-2, NUDOCS 8202110254
Download: ML20040G097 (14)


See also: IR 05000289/1981032

Text

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U.S. NUCLEAR REGULATORY COMMISSION

50289-811008

50289-811009

Region I

50289-811125

50289-811116

Report No. 50-289/81-32

Docket No. 50-289

License No. DPR-50 -

Priority

__

Category

C

--

Licensee :

GPU Nuclear Corporation

P.O. Box 480

Middletown, Pennsylvania 17057

Facility Name: Three Mile Island Nuclear Station, Unit 1

Inspection at: Middletown, Pennsylvania

Inspection conducted: November 17, 1981 - January 8, 1982

Inspectors :

/

[

lfl9 [f t-

J. Chung, Reactor In$ hector

date signed

b/2 / wl---b

tfe4 f t,-

D. Haverkamp, Seniorflesident Inspector (TMI-1)

date signed

~

%

1)20lt2

F. You , , Resi

nt Inspector (TMI-1)

dat'e signed

Approved by: [

/oe

/ /f_z/lr2

A. Fasano, Chief, Three Mile Island Section

date signed

Projects Branch No. 2

Inspection Summary:

Inspection on November 17, 1981 - January 8,1982 (Report Number 50-289/81-32)

Areas Inspected:

Routine safety inspection by resident and regional based

inspectors (282 hours0.00326 days <br />0.0783 hours <br />4.662698e-4 weeks <br />1.07301e-4 months <br />) of. licensee action on previous inspection findings;

plant operations during long term shutdown including facility tours and log

and record reviews; steam generator tube degradation; small fire in TMI-l

Auxiliary Building; IE bul.letin followup; and licensee event reports - in-office

review.

Resul ts : No items of noncompliance were identified in six areas and one item

of noncompliance was identified in one area (failure to follow a welding and

cutting procedure, paragraph 5.c).

.

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8202110254 820125

{DRADOCK05000g

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Detail s

1.

Persons Contacted

General Public Utilities (GPU) Nuclear Corporation

B. Ballard, Manager TMI Quality Assurance (QA) Modifications /

Operations, Nuclear Assurance

R. Barth, Engineer-II -TMI-l

'

  • M. Beers, Engineering Assistant Senior II, Nuclear Assurance

J. Colitz, Plant Engineering Director. TMI-l

  • W. Heysek, Supervisor Site QA Audit, Nuclear Assurance

W. Miller, Nuclear Licensing Engineer, Technical Functions

  • T. O' Conner, Lead- Fire Protection Engineer TMI-l
  • C. Stephenson, Nuclear Licensing Engineer, Technical Functions
  • D. Shovlin, Manager of Plant Maintenance TMI-l

. The inspector- also interviewed'several other licensee employees

during the inspection. They included control room operators,

maintenance personnel, engineering staff personnel and general

office personnel.

  • denotes those present at the exit interview.

2.

Licensee Action on Previous Inspection Findings

(Closed) Unresolved Item 289/79-21-01 : Reactor Coolant System

(RCS) Leak Pate Surveillance Procedure (SP) 1303-1.1 incorrectly

accounted for operator induced changes to the Makeup Tank (MUT).

The inspector reviewed SP 1303-1.1, Revision 8, August 21, 1981,

Temporary Change Notices (TCNs) 1-81-0112 and 1-81-0122, and

1-81-0112 Attachment, and verified that the operator-induced

changes to MUT and RCS inventory were satisfactorily incorporated

into procedural and data sheet steps.

The inspector further

determined that temperature compensation and density corrections

were properly included in the procedure.

Based on these findings,

this item is closed.

(0 pen) Noncompliance 289/79-IR-23:

RCS inventory calculations for

unidentified leakage produced wrong values due to an error in the

calculational procedure. - Surveillance Procedure 1303-1,1 was

scheduled to be reviewed and changes implemented prior to restart

of TMI-1.

The inspector determined by review of SP 1303-1.1,

Revision 8, and independent calculations that the RCS leak rate as

determined by a manual calculation was adequate in the revised

procedure.

The inspector noted that procedural step 6.1 required

use of the process computer for the RCS leak rate determination

unless the process computer inputs and/or the program were inoperable.

A licensee representative stated that a computer software problem

was identifled during hot functional tests and that the RCS leak

rates were recalculated after correcting the programming problems.

The inspector requested a trial run during this inspection and an

additional . software problem was identified.

In addition, the

inspector conducted independent calculations.

The results are

compared in the following table:

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RCS LEAK RATE GPM

LICENSEE

INSPECTOR

PROCESS COMPUTER CALCULATIONS

DATE/ TIME

ORIGINAL

RECALCULATION

MANUAL

CALCULATIONS

<

8-31-81

G 2.24

0.169

0.18

--

01:59:49

U 2.01

- 0.045

-0.10

--

12:19:39

G 0.34

0.15

--

0.19

0 0.13

-0.06

--

-0.12

9-1-81

G 0.73

0.51

0.52

--

16:50:09

0 0.52

0.30

--

.0.22

9-2-81

G 0.39

0.04

0.34

--

00:48:14

U 0.17

-0.17

--

-0.05

9-3-81

G 0.71

1.05

1.05

1.13

16:01:27

U 0.50

0.78

0.79

0.57

9-4-81

G 0.76

0.17

0.50

--

04:36:36

0 0.54

0.23

--

0.41

15:39:39

G 0.77 -

0.41

0.62

--

0.42

U 0.54

0.17

--

9-5-81

G 0.93

0.49

0.70

--

07:58:54

U 0.71

0.27

0.58

--

9-6-81

G 0.93

1.03

0.80

0.81

08:39:37

0 0.69-

0.82

0.59

.0.67

NOTE: G: Gross Leak Rate

U: Unidentified Leak Rate

Based on these results showing that the inspector's calculations

were consistent with the licensee's manual calculations, the

inspector determined that the manual calculations were adequate.

However, the process computer calculations were erratic.

This item

remains open pending an RCS Leak Rate demonstration of consistency

using the process computer during a subsequent NRC:RI inspection.

3.

Plant Operations During Long Term Shutdown

a.

Plant Status During Inspection Period

The plant has remained in the cold shutdown condition with Reactor

Coolant System (RCS) temperature less than 200 F per NRC

order of August 9,1979.

At the beginning of the inspection

period on November 17, 1981, the RCS was at 94 F and 0 psig

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with cooling to the reactor supplied by the

"B" Decay Heat '

~

Removal (DHR) Loop.

The pressurizer was partially filled with

a nitrogen (N ) blanket.

Both Once Through Steam Generators

Z

(OTSG's) were in full wet layup.

During the course of the

inspection the following major plant changes or evolutions

occurred.

November 19, 1981:

Formed a steam bubble in the pressurizer

--

and raised RCS pressure _to 45 psig in order to test

Reactor Coolant Pump 1C. Shifted from "B" DHR Loop to

"A" DHR Loop in order to perform In-Service Inspection

(ISI) on Decay Heat Remov0 Pump 1B.

November 21, 1981 : OTS3 taoe leaks determined and RCS

--

depressurized to 0 psig.

(Refer to paragraph 4-for more

information on OTSG tube degradation.)

November 22, 1981: Pressurizer par'.ially filled and N2

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blanket established in the pressurizer.

November 23, 1981: Diesel Generator 18 taken ~out of

--

service due to high vibration readings on the' rotor.

--

November 25, 1981: Performed flushes on the secondary

side of the OTSG's and placed both OTSG's in wet layup.

November 26, 1981: Drained down RCS to perform N2

--

bubble leak te.t and eddy current testing on both OTSG's.

December 1,1981 : Pressurizer partially filled and N2

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blanket established in the pressurizer.

December 12, 1981: RCS was partially drained for additional

--

inspections of the OTSG tubes.

Eddy current testing

program redefined and recommenced using several different

'

type probes.

December 20, 1981: Drained secondary side of "B" 0TSG

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for tube removal.

Portions of four tubes were removed.

--

December 23, 1981: Shifted from "A" DHR Loop to "B"

DHR

Loop due to a packing leak on Decay Heat Closed Cooling

Pump 1 A.

December 24, 1981 : Temporarily plugged holes from removed

--

0TSG tubes and placed both OTSG's in wet lay up on secondary

side.

--

January 5,1982 : Shifted to "A" DHR Loop from "B"

DHR

Loop due to Diesel Generator 18 still being out of service.

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At the close of this inspection per-iod the RCS was at 120 F

and 0 psig with cooling to the reactor core from "A"

DHR Loop.

The RCS was partially drained-for eddy current testing and

preparation for additional tube removal.

Both OTSG's were in

full wet layup.

b.

Plant Logs and Operat_ing Records

The inspector reviewed selected portions of the following

plant procedures to determine the licensee established require-

ments in this area in preparation for a review of selected

logs and records.

,

Administrative Procedure (AP) 1007, " Control of Records,"

--

Revision 4

AP 1010. " Technical Specification Surveillance Program,"

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Revision 18

,

i

AP 10l?, "ihift Relief and Log Entries," Revision 14

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AP 1033, " Operating Memos and Standing Orders," Revision 2

--

AP 1037, " Control of Caution and [Do Not Operate] DN0

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Tags," Revision 2

AP 1044, "Etent Review and Reporting Requirements,"

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Revision 2

The inspector reviewed the following plant logs and operating

<

records.

,

Shift Foreman Log and Control Room Log Book

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Shift Turnover Checklist

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,

. Temporary. Change Notice (TCN) Log Book

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Active. Tagging Application Book

--

)

Locked Valve Log

i-

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Night Order Book

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Do Not Operate and Caution Tag Log

,

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_ Plant logs and operating records were reviewed to verify the

!

following items.

Log keeping practices and log book reviews are conducted

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in accordance with established administrative controls.

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. Log ei.trie's inv.olving abnormal conditions provide sufficient-

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t

detail to communicate equipment status, lockout. status,

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correction and restoration.

Operating orders do not conflict with Technical Specifi-

--

cations (TS) requirements.

Tagging operations are conducted in conformance with-

^

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established administrative controls.

No items of nonco..spliance were identified,

c.

Facility Tours

During the course of the inspection, the inspector conducted

- tours of the following plant areas.

--

Control Room (daily)

. Auxiliary Building (November _18, 20 and December. 2, -19)

--

Intermediate-Building (November 17 and December 16)

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Vital Switchgear Rooms

(November 19, 30 and December 14)

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Diesel GeneratokBuilding (November 18 and December 1, 30)

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Yard' Area (November 20 and'Iecember. 2,- 9)

--

' Site" Perimeter ( November- 20:and December 2, 9)

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Reactor ' Building (November 24 and December 1, 10, 15, 23)

The following, observations / discussions / determinations were

made.

-

Control room annunciators: Selected lighted annunciators

---

(Radiation Alarm, B Diesel Trouble Alann, Uninterruptable -

' Power Supply _ Trouble ' Alarm) were: discussed with control-

room operators to verify. that the reasons for them were.

~

understood and corrective action, if required, was being

taken.

Control room manning: By frequent observation during the

--

inspectioa, the' inspector verified that control room

manning .equirements of 10 CFR 50.54(k) and the Technical

Specifications were being met.

In addition, the inspector

observed shift turnovers to verify that continuity of

system status was-maintained.

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Technical Specifications: Through log review- and direct

--

observation during tours, the inspector verified compliance

with Technical Specification LC0's associated with Decay

Heat Removal System and Fire. Protection Pump requirements

during shutdown plant operation.

j

Plant housekeeping conditions : Unsatisfactory plant

--

housekeeping conditions observed by the inspector had been

identified previously by station personnel and corrective

action had been initiated as necessary.

Monitoring instrumentation: The inspector verified that

--

selected instruments (Source Range Instruments nil and

NI2, Auxiliary Stack Monitor RMA8, and RCS pressure) were

functional and indicated that parameters were within

Technical Specification limits.

--

Valve positions : The inspector verified that selected

valves were in the position or condition required by

Technical Specifications for the applicable plant mode.

This verification included control board indication and

field observation of valve positions for the Decay Heat

Removal System and the Core Flood System.

--

Fluid leaks: Fluid leaks observed by the inspector had

been identified previously by station personnel and

corrective action had been initiated as necessary.

Piping snubbers / restraints: Selected pipe hangers and

--

seismic restraints were observed and no adverse conditions

were noted.

Equipment tagging: The inspector selected plant components

--

(Core Flood Tanks) for which valid tagging requests were

in effect and verified that the tags were in place and

the equipment in the condition specified.

--

Security :

During the course of this inspection, obser-

vations relative to protected and vital area security

requirements were made, including access controls,

boundary integrity, search, escort, and badging.

No

adverse conditions were noted.

Licensee meetings: The inspector frequently attended the

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Plan-of-the-Day (P00) morning meetings and the daily.

status afternoon meetings held by licensee management and

supervisory personnel.

The inspector _ observed the meetings

to assess licensee evaluation of plant conditions, status

and problems and to review the licensee's plans for

conducting certain major plant operations and maintenance

activities.

The inspector also attended bi-weekly project

status meetings to assess licensee progress and difficulties

related to plant modifications required for restart.

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Acceptance criteria for the above items included inspector

judgement and requirements of 10 CFR 50.54(k), Regulatory

Guide 1.114, Technical Specifications, and the following

procedures.

AP 1002, " Rules for the Protection of Employees Working

--

on Electrical .and Mechanical Apparatus," Revision 22

AP 1008, " Good Housekeeping," Revision 7

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AP 1037, " Control of Caution and DN0 Tags," Revision 2

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No items of noncompliance were identified.

4

St_eam Generator Tube Degradation

a.

Background

Late on November 20, 1981, routine chemistry sampling of the

Once Through Steam Generators (OTSG's) detected radioactivity

on the secondary side of the

"B"

0TSG.

The primary system was

at 45 psig pressure'in anticipation of raising pressure to

300 psig to run a reactor coolant pump.

On November 21, 1981,

a Reactor Coolant System (RCS) leak rate surveillance indicated

that the

"B" 0TSG had a primary to secondary leak between

0.3 gpm and 0.5 gpm.

The plant was immediately depressurized

from 45 psig to atmospheric pressure.

Nitrogen (N ) bubble

2

testing was performed on both OTSG's to evaluate the extent of

tube failure.

The licensee determined that there were 38 leaking

tubes in the "B" 0TSG and 86 leaking tubes in the "A" 0TSG. A

flush of both OTSG's upper tube sheet crevices was done to aid

in arresting the corrision attack.

After the _ flush, s second

N2 bubble test was conducted on both 0TSG's and an additional

six tube leaks were identified in the "B" 0TSG.

Portions of

four tubes have been. removed and shipped to B&W in Lynchburg,

Virginia (two tubes)'and Battelle in Columbus, Ohio (two

tubes) for metallurgical analysis.

Due to the severity of the problem, the Vice President and

Director of TMI-l established an OTSG Tube Leak Task Force.

The task force is composed of representatives from TMI-l

(engineering, operations and maintenance), Technical Functions

(corporate engineering and plant licensing), Maintenance and

Construction, Nuclear Assurance, Radiological Controls,

Communications and Babcock and Wilcox (NSSS engineering).

The

purpose of this task force is to coordinate and direct all

actions regarding the investigations and repairs to the steam

generator tube leaks.

At the close of this inspection the

task force was still compiling data to identify the failure

mode and establish the program to repair the OTSG's.

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b.

Review

Due to the significance and severity of the OTSG tube degradation,

the inspector has been closely monitoring the licensee's 0TSG

leakage evalaution program and initiated a review to verify

the below listed items.

Corrective action is appropriate to correct the cause of

--

the *.ube degradation

Responsibility has been assigned to' ensure proper management

--

attention in correcting the problem

The leakage / tube failures did not cause violation of

--

Technical Specifications, license conditions or regulatory

requirements

,

Information related to the event submitted -to NRC is

--

,

accurate

Stability of plant conditions, including provision for :

--

decay heat removal

Proper review and implementation of radiological' controls

--

including ALARA

Selected sections of the following documents were. reviewed.

.

Radiation Work Permits (RWP's) associated with' initial'

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entries into the upper portions of both OTSG's

ALARA review conducted for OTSG N2 bubble testing,

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installation of video equipment and eddy current testing

in OTSG's

Administrative Procedure (AP) 1103-11, " Draining and N2

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Blanketing RC System," Wevision 12

AP 1104-4, " Decay Heat Removal System," Revision 32

--

AP 1106-16, "0TSG Secondary Fill Drain and Layup,"

--

Revision 20

In addition to conducting interviews with personnel involved,

the inspector attended several licensee Steam Generator Tube

Leak Task Force meetings to assess the status of actions being

taken.

The inspector also conducted' field observation of N2

bubble testing in the

"B" 0TSG, Eddy Current testing on both

OTSG's on several occassions and fiber optics video recording

on the "A" 0TSG to independently evaluate the situation.

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c.

Findings '

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(1) On December 11,1981, at .1 :25 PM, the inspector entered

the Control Room on a daily tour. While reviewing the-

status of the Steam Generator tube leak problem, the

inspector noticed that the pressurizer heaters were not

tagged out as required by Operating Procedure (0P) 1103-11,

step 2.1.3.

At the time the licensee was in the process-

of draining both OTSG's in accordance with OP 1103-11.

The inspector informed the shift supervisor who immediately

ordered a tagout to be issued for the pressurizer heaters.

Discussion with control room operators revealed that the

tagout of the heaters were to back up a low level pressurizer

heater cutout switch.

The inspector concluded that there

had not been a degradation in plant safety and considered

the item to be an isolated case.

On December 14, 1981,

the inspector audited the tagout for. pressurizer heaters.

and found it to be correctly performed in accordance with

the applicable station procedure.

The inspector had no

further comments in this area..

(2) On January 5,1982, a meeting was held on site between

NRC representatives and key members of the Steam Generator

Tube Leak Task Force to review the scope and status of

the licensee's program.

At the conclusion of the meeting

it was determined that substantial work remained and that

another meeting will be required after more data has

been collected.

At the close of the inspection, the tube failure and

repair program was still in the developmental stage.

The

licensee's continuing efforts to identify the cause of tube

degradation and to complete adequate corrective measures

,

will be reviewed during subsequent NRC inspections (289/81-32-01).

5.

Small Fire in Unit 1 Auxiliary Building

a.

Background

_

At 1:35 PM on December 16, 1981, during welding on the 305' elevation

of the auxiliary building, weld slag material fell through an

open penetration to the 281' elevation and ignited a cloth

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(Chem-wipe) laying on a cable tray below.

The fire watch

immediately put the fire out using a dry chemical extinguisher.

The licensee responded to the fire which included dispatching

the onsite fire team and sounding the onsite fire alarn.

No

offsite assistance was needed.

Dust and smoke resulted in the

area necessitating local evacuation.

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The welding was on a support for a shield with respect to the

additional pipe shielding restart modification.

The licensee

reported no significant damage to the cables in the cable

tray. Also, there were no indications of explosive gas or a

release of radioactivity.

An investigation has been conducted

by the TMI Safety and Health Department staff. Several

recommendations were made in the investigation which have not

been implemented fully at this time,

b.

Review

Licensee activities in response to the fire were reviewed to

assess items listed below.

Safety significance of the event, and compliance with TS

--

or other licensee requirements

Reportability of the event and licensee plans regarding

--

a press release

Amount of radioactivity released, if applicable

--

Event internal management review and followup including

--

event description, cause and systems or plant components

affect.ed and overall sequence of events

Immediate and subsequent corrective action

--

c.

Findings

After the fire alarm was activated, the inspector proceeded to

the Unit 1 Control Room and then observed the licensee's

actions to extinguish a small fire on the 281' elevation of

the auxiliary building.

The inspector noted that licensee

response to putting out the fire was timely and adequate.

All

members of the fire brigade were present at the scene of the

fire with designated equipment as defined in the licensee's

procedures.

Followup fire site observation by the inspector revealed that

a floor opening located within 40 feet of the welding location

had not been covered.

This is a violation of item D listed on

the Welding and Cutting pennit which had been completed and

signed by proper site personnel .

The failure to cover the

floor penetration is also a violation of section 6.3.1.c of

TMI-l Maintenance Procedure 1410-Y-26, Revision 5, " Control of

Welding, Flame Cutting, Grinding, Brazing and Soldering.

Althougl the fire was not severe, the failure to follow these

fire prevention procedures is a serious matter and is considered

an item of noncompliance with respect to 10 CFR 50, Appendix B,

Criterion V (289/81-32-02).

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Subsequent to the fire, an investigation was conducted by the

TMI Safety and Health Department staff.

The following findings

were identified by the licensee in the investigation report.

Welding permit had been filled out correctly and signed

--

by the proper site personnel

Floor openings located directly beneath the welding

--

location were not tightly covered which was in direct

violation of the welding permit and Site Procedure 1410-Y-26.

Plywood had been used to cover two of the tnree floor

penetrations and one penetration was not covered at'all

--

Contrary to the welding permit, combustible materials

were located within 40 feet of the welding operation with

no protection provided by asbestos curtains, metal guards

or flame proof covers

--

Flameproof cloth covers were not available for use in

sufficient quantities from the licensee's maintenance

tool room

Fire extinguisher issued to the fire watch failed to

--

function properly.

It was subsequently determined that

the extinguisher had a faulty C02 charge cartridge

Source of the fire was apparently a muslin cloth laying

--

on top of a cable tray located underneath the penetration.

It was surmised that the fire was produced by welding

sparks dropping through the floor penetrations and

igniting the muslin cloth

The following recommendations were made by the Safety Department

to plant management.

--

Contractor should be required to describe in detail what

actions will be taken to prevent a recurrence of this

event

Fire Protection Engineering should be tasked with reviewing

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contractor's action for adequacy

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An adequate supply of welding cloths should be established

and maintained in both the licensee's and the contractor's

tool room

At the close of the inspection, management's final evaluation

and correcti'.e actions were still under review.

Immediate

steps taken by the contractor had been to terminate the

employment of the two craftsmen responsible for the fire.

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6.

IE Bulletin Followup

The inspector reviewed the licensee's followup action regarding the

IE Bulletins (IEB) listed below.

IEB 80-24, " Prevention of Damage due to Water Leakage Inside

--

Containment," dated November 21, 1980

IEB 81-01, " Surveillance of Mechanical Snubbers," dated January 27, 1981

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IEB 81-02, " Failure of Gate Type Valves to Close Against

--

Differential Pressure," dated August 18, 1981

With respect to the above bulletins, the inspector verified that

licensee management forwarded copies of the bulletin response to

appropriate onsite management representatives, that information and

corrective action discussed in the reply was accurate and implemented

as described, and that the reply was submitted within the time

period described in the bulletins.

.

Acceptance criteria for the above review included inspector judgement

and requirements of applicable Technical Specifications 'and facility

procedures.

Licensee followup to the above bulletins was acceptable.

7.

Licensee Event Reports (LER's) - In-Office Review

The inspector reviewed the LER's listed below, which were submitted

to the NRC Region I office, to verify that the details of the event

were clearly reported, including the accuracy of the description of

cause and the adequacy of corrective action.

The inspector determined

whether further information was required from the licensee, whether

the event should be classified as an Abnormal Occurrence, whether

the information involved with the event should be submitted to

Licensing Boards, whether-generic implications were indicated, and

whether the event warranted onsite followup.

The following LER's were reviewed:

LER 81-010/03L-0, dated November 10,1981 (Quality control

--

audit determined that a Reactor Building prestressing tendon

had an unacceptable lift-off force.

Technical Specifications

require that two adjacement tendons be inspected, which was

not performed)

LER 81-Oll/0lT-0, dated November 4,1981 (Review of a catwalk

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structure for application of additional loads revealed that

seismic. design calculations were not performed by the original

architect engineer)

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LER 81-012/04T-0, dated November 30,'1981 (River Water

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Chlorinator malfunctioned' causing Environmental Technical

Specification limiting condition for total chlorine concen-

tration to be exceeded)

LER 81-013/01 T-0, dated December 9,1981 (Primary to secondary

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tube leakage occurred in both Once Through Steam Generators)

Several blocks and codes on LER 81-010/03L-0 and LER 81 -011/01 L-0

were noted to have minor errors. .The discrepancies were identified

to the licensee and the licensee is in the process of resubmitting

corrections to both LER's.

The inspector has reviewed the draft

resubmittals and found them to be correct.

The above LER's are

closed based on this in-office review 'and correction of reporting

errors.

8.

Ex._i_t Interview

Meetings were held with senior facility management periodically

during the course of the inspection to discuss the inspection scope

and findings.

The inspectors met with the licensee representatives

(denoted in paragraph 1) at the conclusion of the inspection on

'

January 8,1982, and summarized the purpose and scope of the

inspection and the findings.

The licensee representatives acknowledged

the findings.

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