ML20050A820
| ML20050A820 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/08/1982 |
| From: | Chung J, Fasano A, Finkel A, Haverkamp D, Nicholas H, Oneill B, Shanbaky M, Young F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20050A810 | List: |
| References | |
| 50-289-82-01, 50-289-82-1, NUDOCS 8204020302 | |
| Download: ML20050A820 (33) | |
See also: IR 05000289/1982001
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O.S. NUCLEAR REGULATORY COMMISSION
50289-790322
50289-790706
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50289-790426
50289-790809
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Region I
50289-790516
50289-791019
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50289-790630
50289-791126
50289-790705
50289-791211
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Report No.
50-289/82-01
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Docket No. _50-289
License No. DPR-50
Priority
Category
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Licensee :
GPU Nuclear Corporati_on
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P.O._ Box 480
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Middletown, Pennsylvania 17057__
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Facility Name: Th_ree Mile _ Island Station, Unit 1
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Inspection at: Middletown, Pe_nnsyl vania
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Inspection conducted: January 6,1982 - February 16, 1982
Inspectc rs :
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2/r r/s2.
fx J. Chung, Reactor yspector
date signed
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(January 11-13, 1982)*
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.hR.t L l &
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pm A. Finkel, Reactor 7nspector
date signed
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(January 6-13 and 18-22,1982)
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D. Haverkamp, Senior psident Inspector (TMI-1)
date signed
1.E./1<~L
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(January 27-29, 19 )
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B. O'Npll, Kadipion Specialist
date signed
M ($snbebY
JN/EY2-
M.
hanbaky, Senior R/iation Specialist
ddte signed
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3M/%
F. Y
ng, R ident Inspector (TMI-1)
date signed
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Accompanying Inspectors:
The inspector listed below were onsite (63 hours7.291667e-4 days <br />0.0175 hours <br />1.041667e-4 weeks <br />2.39715e-5 months <br />)
during the periods indicated for site specific training and
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inspection training.
S. Pullani, Reactor Inspector
S. Richards, Reactor Inspector
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(January 1-13, 1982)
(January 6-13, 1982)
Approved by:
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A. FasanoI, Chief, Three Mile Island Section
dhth signed
Project Branch No. 2
- InspecGon periods are indicated for region-based inspectors.
820402030Q 820317
PDR ADOCK 05000289
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Inspection Summary:
Inspection on January 6,1982 - February 16,1982 (Report Number 50-289/82-01)
Areas Inspected: Routine safety inspection by resident and region-based
inspectors (456 hours0.00528 days <br />0.127 hours <br />7.539683e-4 weeks <br />1.73508e-4 months <br />) of licensee action on previnus inspection findings;
plant operations during long term shutdown including: facility tours and log
and record reviews; steam generator tube degradation; licensee event reports
- onsite followup; high radiation area controls; TMI-l restart modifications;
TMI-l restart preoperational testing; and TMI-l restart overall startup testing
program.
Resul ts : No items of noncompliance were identified in eight areas and two
items of nonco.apliance were identified in one area (violation - failure to
adhere to high radiation area controls, paragraph 6; and violation - failure
to promptly correct inadequate high radiation area controls, paragraph 6).
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Detail s
1.
Persons Contacted
GPU Nuclear Corporation
B. Ballard, Manager TMI Quality Assurance (QA) Modifications /
Operations, Nuclear Assurance
R. Barley, Lead Mechanical Engineer TMI-l
M. Beers, Engineering Assistant Senior II, Nuclear Assurance
S. Cafrelli, Technical Analyst, Technical Functions
J. Colitz, Plant Engineering Director TMI-l
T. Faulkner, Planning and Scheduling Manager, Maintenance and
Construction
R. Fenti, Quality Control Manager, Nuclear Assurance
L. Florey, Radiological Controls Technician
- J. Garrison, QA Engineer Assistant Senior III, Nuclear Assurance
T. Hawkins, Manager TMI-l, Startup and Test, Technical Functions
W. Heysek, Supervisor Site QA Audit, Nuclear Assurance
- H.
Hukill, Vice President and Director . 4I-1
- J. Kuehn, Deputy Manager, Radiological Controls (TMI-1)
M. Kuhn, Radiological Field Operations Foreman
S. Levin, Maintenance and Construction Director (TMI-1)
- W. Miller, Nuclear Licensing Engineer, Technical Functions
F. Paulewicz, Mechanical Engineer TMI-l
I. Porter, Supervisor, Startup and Test TMI-l
W. Potts, Manager, Radiological Controls, TMI-l
R. Rolph, Radiological Field Operations Foreman
M. Ross, Manager Plant Operations TMI-l
- C. Smyth, Supervisor, TMI-l Licensing, Technical Functions
K. Stephenson, Nuclear Licensing Engineer, Technical Functions
A. Stowe, Coordinator TMI Records Management, Administration
Division
- R. Toole, Operations and Maintenance Director TMI-l
D. Tuttle, Radiological Engineering Manager TMI-1, Radiological
Controls
P. Velez, Radiological Field Operations Manager TMI-1,
Radiological Control s
Catalytic Incorporated
T. Germak, Civil Supervisor
T. Reddington, Project Superintendent
The inspector also interviewed several other licensee and contractor
employees during the inspection.
They included control room operators,
maintenance personnel, engineering staff personnel, radiological
controls personnel, and general office personnel.
- denotes those present at the exit interview.
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2.
Licensee Action on Previous Inspection Findings
(Closed) Noncompliance 289/79-IR-18:
Failure to implement procedures
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for restoration of equipment to service after maintenance of EFW
. val ve s .
The licensee's December 5,1979 response described the
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following corrective actions concerning improvement in records:
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"The records management function at Three Mile Island is being
expanded to include a significantly larger staff of professional
and clerical personnel dedicated to the collection and retention
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of records.
This function will be led by a department level
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manager supported by appropriate supervisory personnel directing
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separate groups for TMI-l and TMI-2.
Among the improvement in
records retention will be computer-aided filing, improved
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storage and control, and advanced reproduction methods.
The emp6 asis on records retention and control will be complemented
by general training that emphasizes the necessity to properly
complete each aspect of any work, including the documentation.
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Finally, the staff and supervision of the on-site Quality
Assurance Department has taken on an expanded role to assure
that each area of performance prescribed by station procedures
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and practices are followed."
The inspector reviewed the records management system and determined
through discussions with licensee personnel and observation of
records management facilities that programmatic improvements in
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record retention had been achieved.
The inspector noted that the
computer assisted records information retrieval system (CARIRS)
had not been implemented ' fully for all departments.
Based on this
review, the inspector co'ncluded that satisfactory implementation
was completed or in progress.
The inspector had ho further comments
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concerning this item.
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(Closed) Noncompliance 289/79-IR-23: Reactor Coolant System (RCS)
inventory calculations for unidentified leakage produced wrong
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values due to an error in the calculative portion of the computer
program. As described in NRC Inspection Report 50-289/81-32,
paragraph 2, manual, calculations of RCS leak rate were determined
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to be adequate. However, the process computer calculations were
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erratic. A licensee representative stated that the problems
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associated with ~the RCS leak rate computer program had been identified
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and the revised computer program would be tested further.
One
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program statement had an error in the algorithm and the drain tank
level was not converted into inches.
The following RCS leak rate
test, performed November 27, 1981, was calculated with the revised
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computer program and compared with an independent calculation by
the inspe(tor.
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RCS LEAK RATE (GPM)
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Licensee Calculations
Inspector
Compute r
Manual
Calculations
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Gross
1.0046
1.0546
l.00
Unidenti fied
0.7223
0.7701
0.71
Based on the above result comparisons, this item is closed.
(Additioral
review of the computer program and result comparisons will be
performed during NRC inspection of RCS leak rate tasts conducted
during startup testing.)
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(Closed) Inspector Followup Item 289/80-10-01 : Conduct review of
Licensee Event Reports (LER)79-005, 79-007,79-011, 79-012,79-013,
79-015,79-016, and 79-017.
The inspector reviewed the licensee's
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corrective action which had been aken for each LER as described
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in paragraph 5 of this report.
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(Closed) Inspector Followup Item 289/81-10 01: Upgraded quality
control requirements for incore thermocouples modification materials
and installation.
The inspector reviewed Engineering Change Memorandum
(ECM)-S-012, Revision 4, for the material inspection and installation
quality control requirements.
The requirements specified the
upgrading of this modification to be "Important to Safety".
The-
inspector reviewed the inspection docur.entation which' indicated
that the material and installation complied with the requirements
of the ECM and had no further questions concerning this item.
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(Closed) Inspector Followup Item 289/87-1 0-02: Construction
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organization notification of Task RM-6. ECM-S-036 upgrade to
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"Important to Safety" .
Task mi-6; Main Steam Safety Valves Audio
Monitoring System, consisted of ECM-S-036, Revison 0,1, l A, and 2
and ECM-S-052, Reviscos 0 an'd 1.
The inspector reviewed the'
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documentation associated with this task and determined it complied
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with applicable quality ass;irance requirements.
The package was
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accepted by the lice'see's plant' staff on December 11, 1981.
The
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inspector reviewed the documentaticn and determined- that previcas
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incomplete work list items were ' completed and accepted 'by qu6lity 3
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control. 'The inspector had no further ) questions concerning 'this.
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item.
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3.
Plant _ Operations During Long Term Shutdown
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Plant Ststus During Inspectiol Period
The plant has remained in told shutdown conditidn with Reactor
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Coolant System (RCS) tSnperature less than 200 F per NRC order
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of August 9,1979
At the beginning of the inspection period
on January 6,1981, the RCS was at 97 F and 0,psig with cooling
to the reactor supplied }y the " A" Decay Heat' Renoval (DHR) loop,
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The RCS was partially drained for eddy current testing and for
additional tube removal .
Both Once Through Steam Generator
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(OTSG's) were in full wet lay-up.
During the course of the
inspection the following major plant changes or evolutions
occurred.
January 12, 1982: Diesel Generator l A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> load test
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surveillance was conducted.
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January 19, 1982: Secondary side of "A" 0TSG was drained
for tube removal.
Portions of 15 tubes were removed.
January 20, 1982: Holes from removed "A" 0TSG tubes were
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temporarily plugged; "A" 0TSG was placed in wet lay-up
on the secondary side.
January 21, 1982:
Fire Service Pump FS-P-3 was taken out
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of service to perform I&C maintenance.
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Janua ry 22, 1982:
FS-P-3 was placed back in service.
Hayes gas analyzer was declared inoperable due to out of
specification readings.
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January 26, 1982: Hayes gas analyzer was returned to
service.
January 29, 1982: Local Leak Rate Test was performed
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satisfactorily on Reactor Building personnel door.
Relay
testing was conducted on l A Startup Transformer.
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February 3,1982 : Decay Heat Removal system placed in
cleanup mode through "B" Precoat Filter.
At the close of this inspection period the RCS was at 100 F
and 0 psig with cooling to the reactor core from the "A"
loop.
The RCS was partially drained for preparation for
permanently plugging 19 holes formed from 0TSG tube removal .
Both OTSG's were in full wet lay-up,
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b.
Plant Logs and Operating 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,"
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Revision 4
AP 1010, " Technical Specification Surveillance Program,"
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Revision 18
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AP 1012, " Shift Relief and Log Entries," Revision 14
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AP 1033, " Operating Memos and Standing Orders," Revision 2
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AP 1037, " Control of Caution and [Do Not Operate] DN0
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Tags," Revision 2
AP 1044, " Event Review and Reporting Requirements,"
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Revision 2
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The inspector reviewed the following plant logs and operating
records,
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Shift Foreman log and Control Room Log Book
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Shift Turnover Checklist
Temporary Change Notice (TCN) Log Book
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Active Tagging Application Book
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Locked Valve Log
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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.
Log entries involving abnormal conditions provide sufficient
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detail to communicate equipment status, lockout status,
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correction and restoration,
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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.
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No items of noncompliance were identified.
c.
Facility Tours
During the course of the inspection, the inspector conducted
tours of the following plant areas.
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Control Room (daily)
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Auxiliary Building (January 4, 8, 14, 20, February 2)
Intermediate Building (January 8,14, 28)
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Vital Switchgear Rooms (January 7,13, 26, February 1)
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Diesel Generator Building (January 7,14, 26, February 1)
Yard Area (January 4, 15, 28)
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Site Perimeter (January 13, 22)
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Reactor Building (January 7, 13, 18, 20, 22, 28)
The following observations / discussions / determinations were
made.
Control room annunciators:
Selected lighted annunciators
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(Condensate Low-Low Alarm and 0TSG Level Low 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
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inspection, the inspector verified that control room
manning requirements 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 LCO's associated with fire
detection instrumentation and Halon system requirements
during shutdown plant operation.
Plant housekeeping conditions: Unsatisfactory plant
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housekeeping conditions observed by the inspector had
been identified previously by station personnel and
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corrective action had been initiated as necessary.
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Monitoring instrumentation: The inspector verified that
selected instruments (OTSG level indicators and High
Radiation Monitor Alarms RMA-8 and RMA-9) were functional
and indicated that parameters were within Technical
Specification 1imits.
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Valve positions: The inspector verified that selected
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valves were in the position or condition required by
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Technical Specifications for the applicable plant mode.
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This verification included control board indication and
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field observation of valve positions for the Nuclear
Service Closed Cooling System, Intermediate Closed Cooling
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System and Instrument Air System.
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Radiation control s:
The inspector verified by observation
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that control point procedures and posting requirements
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were being followed.
The inspector identified a failure
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to adhere to high radiation area controls as discussed in
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paragraph 6 of this report.
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Fluid leaks:
Fluid leaks observed by the inspector had
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been identified previously by station personnel and
corrective action had been initiated as necessary.
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Piping snubbers / restraints: Selected pipe hangers and
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seismic restraints were observed and no adverse conditions
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were noted.
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Equipment tagging: The inspector selected plant components
( Air Handling for AH-E14C and Decay Heat Closed Cooling
Water Pump DC-P-1B) for which valid tagging requests were
in effect and verified that the tags were in place and
the equipment in the condition specified.
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Security:
During the course of this inspection, observa-
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tions relative to protected and vital area security
requirments were made, including access controls, boundary
integrity, search, escort, and badging.
No adverse
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conditions were noted.
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Licensee meetings: The inspector frequently attended the
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Plan-of-the-Day (P0D) morning meetings and the daily
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status afternoon meetings held by licensee management and
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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
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conducting certain major plant operations and maintenance
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activities.
The inspector also attended bi-weekly project
status meetings to assess licensee progress and difficulties
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related to plant modifications required for restart.
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Acceptance criteria for the above items included inspector
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judgement and requirements of 10 CFR 50.54(K), Regulatory
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Guide 1.114, Technical Specifications, and the following
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procedures.
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AP 1002, " Rules for the Protection and Employees Working on
Electrical and Mechanical Apparatus," Revision 22
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AP 1008, " Good Housekeeping," Revision 7
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AP 1037, " Control of Caution and DN0 Tags," Revision 2
No items of noncompliance were identified, except as described
in paragraph 6 of this report.
4.
Steam Generator Tube Degradation
a.
Background
Repressurization of the Reactor Coolant System (RCS) in
November 1981 revealed degradation in tubes in both Once
Through Steam Generators (OTSG's).
In December 1981 a task
force was established to coordinate and direct all actions
regarding the investigation and repairs to the steam generator
tube leaks.
(See NRC Region I Inspec. tion Report 50-289/81-32.)
Eddy Current tests have been ongoing since early December.
The initial phase of testing was completed in early February 1982.
This program consisted of inspecting portions of all unplugged
0TSG tubes (31, 062) with a standard eddy current probe.
The
second phase of the eddy current testing program used a newly
developed probe which is more sensitive in the roll transition
zone where the majority of the corrosion appears to have
occurred.
The second phase of the eddy current program is
being conducted at this time in conjunction with tube plugging
preparations.
Testing is expected to be completed and data
analyzed in March.
Four OTSG tube sections were removed for analysis in December 1981,
and extensive laboratory testing of these tubes is still in
progress.
Preliminary metalurgical indications from both B&W
and Battelle Laboratories indicate that the mode of failure is
sul fur assisted intergranular attack.
The corrosion attacking
the grain boundaries of the metal appears to have propagated
from the inside of the tube and to have worked outward, indicating
that a corrosive agent was in the RCS water.
Portions of
15 additional OTSG tubes were removed on January 19,1982 for
metallurgical analysis and shipped to B&W in Lynchburg, Virginia
(9 tubes) and Battelle Labs in Columbus, Ohio (6 tubes).
In parallel with the above testing, the licensee is making
preparations to inspect the internal components of the reactor
vessel .
Preparations are being made to remove the reactor
vessel head in April 1982 with subsequent partial or total
transfer of the fuel assemblies from tSe reactor vessel to the
spent fuel pool .
The licensee expect to determine final
plans for RCS component examinations by mid-March.
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Final repairs to 'the OTSG's are being evaluated by several
task groups that have been organized at the GPU Nuclear corporate
o f fice.
There are four possibilities for tube repair being
considered, including plugging, plugging and sleeving, replacing
all the tubes or replacing the OTSG's.
Members from these groups plus
licensee contractor organizations and consultants met with the
NRC in Bethesda, Maryland, on January 25, 1982 to present an updated
status of proposed repairs and testing. Meetings were also
held with the NRC on January 29, and February 2,1982 to
update the NRC staff.
b.
Review
Due to the significance and severity of the OTSG tube degradation,
the inspector has been closely monitoring the licensee's 0TSG
leakage evaluation program and had initiated a review to
verify the below listed items.
Corrective action is appropriate to correct the cause of
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the tube degradation
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Responsibility has been assigned to ensure proper management
attention in correcting the problem
The leakage / tube failures did not cause violation of
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Technical Specifications, license conditions or regulatory
requirements
Information related to the event submitted to NRC is
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accurate
Stability of plant conditions, including provision for
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Proper review and implementation of radiological controls
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including ALARA ( As Low As Reasonably Achievable)
considerations
Selected sections of the following documents were reviewed.
Radiation Work Permits (RWP's) associated with entries
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into the OTSG's
ALARA review conducted for OTSG tube removal and eddy
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current testing in OTSG's
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Materials and Welding Specification (MTWS) - 012, "Quali-
fication of Welding Procedure Specifications and Welders
for Tube /Tubesheet Plugging of Steam Generators and/or
Heat Exchangers," Revision 0
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MTWS-013, " Tube /Tubesheet Plugging Standard for Steam
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Generators and/or Heat Exchangers," Revision 0
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AP 1104-4, " Decay Heat Removal System," Revision 32
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Specification (SP) 1101-12-028, "Once Through Steam
Generator Phase I Tube Plugging and Stabilizing," (Draft)
AP 1106-16, "0TSG Secondary Fill Drain and Layup,"
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In addition to conducting interviews with responsible licensee
personnel, 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
observations of eddy current testing on both 0TSG's on several
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occassions and tube removal operations in the "A" 0TSG to
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independently evaluate these licensee activities.
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c.
Finding
The inspector reviewed selected portions of licensee documents
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and observed portions of the OTSG repair program to verify
that the requirements stated before were met by the licensee.
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The inspector determined that the licensee was exercising
adequate control in preparation and conduct for this portion
of their program.
During the January 25, 1982 meeting with the NRC staff, in
Bethesda, Maryland, licensee management explained their broad
based program in the areas of eddy current testing, tube
failure analysis, accident analysis and tube repair techniques.
At the present time, it is estimated that several thusand
tubes may have defects needing repair.
It was statea that at
least two months were needed for the utility to identify the
cause of the problem and the repair method.
Subsequent meetings
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with the licensee have not revealed any new information.
At the close of this inspection the tube failure and repair
program was still being developed.
The licensee's continuing
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efforts to determine the cause of the tube degradation and
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complete adequate repairs will be reviewed during subsequent
NRC inspectbns.
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5.
Licensee Event Reports - Onsite Followup
The inspector reviewed the LER's listed below, which were submitted
to the NRC Region I office, to verify that the reporting requirements
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of Technical Specifications and applicable licensee procedures had
been met, that appropriate corrective action has been taken, that
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the event was reviewed by the licensee as required by Technical
Specifications, and that continued operation of the facility was
conducted in conformance with Technical Specification limits.
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The following LER's were reviewed:
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LER 79-005/03L-0, dated March 22,1979 (Decay Heat Removal
System total leakage during refueling outage mode was 8.9 gal /hr,
which exceeded the 6.0 gal /hr limit of T.S. 4.5.4.1, due to
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excessive packing gland leakage from five valves)
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LER 79-007/0lT-0, dated April 26,1979 (Borated Water Storage
Tank dome was partially collapsed, due to the apparent failure
of vacuum breaker DH-V27 to relieve differential pressure when
required)
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LER 79-011/03L-0, dated May 16, 1979 and LER 79-Oll/03X-1,
dated June 30,1979 (Abnormal degradation (through wall piping
,
leaks) of Spent Fuel Pool Cooling System piping and other
304SS piping in other plant systems due to intergranular
--
LER 79-012/0lT-0, dated July 6,1979 (Failure of Engineered
Safeguards Actuation System relay (GTE Sylvania Relay Type PM)
to drop out when the coil was deenergized due to a notch in
the operating rod (potentially generic problem'
--
LER 79-013/OlT-0, dated July 5,1979 (Crack in suction piping
from Borated Water Storage Tank, attributed to intergranular
stress corrosion cracking produced by residual weld stresses)
--
LER 79-015/0lT-0, dated August 9,1979 (Error in accident
analysis for small break LOCA's, which could result in uncovering
the core and exceeding 10 CFR 50, Appendix K criteria, due to
nonconservative assumpti as of flow)
l
--
LER 79-016/0l T-0, dated October 19,1979 (Nonconservative
'
error in seismic analysis of pipe supports for the
"B"
Decay
'
Heat Closed Cooling and Nuclear Services Closed Cooling Water
Piping, due to error between as-built piping and drawing
analyzed)
,
LER 79-017/0lT-0, dated November 26, 1979 and LER 79-017/0l X-1,
--
,
dated December 11,1979 (Size of support bolting for rigid
anchors was found to be inadequate in both design and installation,
,
and under seismic conditions the affected piping may exceed
,
'
code allowable stresses)
t
The inspector's findings regarding these licensee events were
acceptable, unless otherwise noted below,
j
,
LER 79-Oll/03L-0 and LER 79-013/0lT-0 were part of the bases
-
for IE Bulletin (IEB) 79-17 (Pipe Cracks in Stagnant Borated
Water Systems at PWR Plants).
The licensee corrective actions
for these LER's were reviewed during NRC inspections of
,
-.
.-
- - .
.
- - .
.-
--
-_.
.
=.
.
-
.
.
9
14-
-
1
i
LER 79-015/0lT-0 and LER 79-017/0l T-0 were reported pursuant
,
--
]
to the requirements of IE Bulletin 79-14 (Seismic Analyses for
As-Built Safety-Related Piping Systems).
The corrective
-
actions for these LER's will be reviewed in conjunction with a
'
subsequent NRC inspection of the licensee's final response to
4
6.
High Radiation Area Controls _
'
a.
Documents Reviewed
The inspector reviewed the following documents concerning High
Radiation Area controls.
Radiation Work Permit (RWP) No.10741
--
,
Radiation Survey Forms dated January 17, 1982 for areas
--
!
I
and equipment inside "D" ring
i
!
--
Radiological Investigative Report No.82-002 dated
February 9,1982
TMI-1 Radiological Controls Log entry dated January 22, 1982
--
!
TMI-l Radiological Controls Procedure No.1610-1, " Access
--
Control for High Radiation Areas," Revision 4, dated
.
)
September 8,1981
I
TMI-l Radiological Controls Procedure No.1613, " Radiation
--
Work Permits," Revision 18, dated November 25, 1981
TMI-l Operational QA Plan, Revision 9, dated May 28, 1981
--
,
b.
Locking of High Radiation Area Doors
'
On January 22, 1982, while touring the Reactor Building (RB),
the inspector examined High Radiation Area controls.
The
inspector noted an inadequately locked High Radiation Area
door at the top of the "D" ring.
He was able to open the door
by reaching around to the other side and turning the doorknob.
This entrance leads to several areas including the top of the
"D" ring, the polar crane and the Reactor Coolant Pumps (RCPs).
The inspector examined some of the recent radiological surveys
of these areas including radiological surveys conducted on
January 17, 1982.
The surveys indicated a dose rate of
greater than 1000 mR/hr at the location of the RCPs.
,
4
i
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i
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-
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.
4
.
i
.
-15-
s
On January 22, 1982, upon exiting the RB, the inspector discussed
High Radiation Area control with the licensee's Radiological
Field Operations Foreman.
The inspector informed the Radiological
Field Operations Foreman that the High Radiation Area access
door at the top of the "D" ring was inadequately locked and
,
!
could easily be opened by reaching around to the other side
and turning the doorknob.
The Radiological Field Operations
l
Foreman stated that " locking of High Radiation Area doors is
mainly to make people stop and think before entering the
area".
The inspector stated that High Radiation Areas of
,
greater than 1000 mR/hr must be adequately locked to prevent
1
'
unauthorized entry.
The Radiological Field Operations Foreman
1
was informed that the door to the "D" ring did not meet the
l
NRC requirements for High Radiation Area locking and administrative
i
controls criteria.
!
!
On January 28, 1982, upon learning that no prompt corrective
action was taken to adequately lock the High Radiation Area
door, the inspector discussed with licensee representatives,
j
including Radiological Control s Department management, the
J
radiological and administrative controls requirements for High
!
Radiation Areas.
The inspector stated that the inadequately
locked High Radiation Area door in the RB constituted apparent
noncompliance with NRC regulations and corrective action
j
should be taken to prevent unauthorized personnel access to
the High Radiation Area.
Licensee representatives disagreed
'
that the door in question constituted a noncompliance with the
regulations.
1
The above item is one example of violation of Technical Specification 6.13.1 requirements for High Radiation Area
i
!
control s.
c.
Key Control for High Radiation Areas
,
!
On January 22, 1982, the inspector noted that keys to RB areas
were left unattended.
These keys were found by the inspector
,
on the top of an equipment cabinet, located outside the
,
'
persnnnel airlock.
Subsequently, the inspector determined
that these keys were High Radiation Area keys, and the inspector
!
i
stated that failure to maintain the High Radiation Area keys
under the administrative control of the Manager Radiological
I
Controls / Radiological Field Operations Foreman or the Shift
Foreman on duty, as required by Section 6.13 of the Technical
Specifications, constituted an apparent item of noncompliance,
,
l
The licensee stated that immediate corrective action had been
{
initiated to improve High Radiation Area key controls.
The above item is a second example of violation of Technical
,
'
Speci fication 6.13.1 requirements.
l
1-
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.
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.
.
-16-
d.
Unauthorized Entry into a High Radiation Area
On February 1,1982 a licensee Radiological Controls Technician
observed and reported that a contractor supervisor entered the
"D" ring area by the unauthorized means brought to the licensee's
attention on January 22, 1982.
The Radiological Controls
i
Technician escorted the individual out of the area to the
!
Control Point.
The individual had signed on a Radiation Work
Permit (RWP No.10741) to work in the Unit 1 RB (all elevations
and the top of the polar crane).
I
When the individual was questioned by the inspector as to the
,
appropriateness of his actions, the individual stated that he
j
did not believe that he was entering a High Radiation Area
since the door was not posted "High Radiation Area".
(The
inspector determined the door had been posted as a High Radiation
1
Area on January 28, 1982 and on February 3,1982. )
The individual
stated that the access method he used was used by other individuals,
and he considered this to be routine practice.
The inspector verified that the individual had taken the
required RWP training.
Through discussion with the individual
and licensee representatives, and examination of records, the
inspector noted that the individual had intended to go to the
polar crane (low dose rate area) and did not go to the RCP
,
area (some locations in this area are several R/hr).
The
}
inspector examined the individual's dose records and noted that
i
his pocket dosimeter and thermoluminescent dosimeter did not
indicate any dose to the individual.
Based on interviews with
!
the individual and Radiological Controls personnel, and examination
jl
of licensee's Radiological Investigation Report No.82-002,
RWP 10741, radiological surveys, and other licensee records,
j
the inspector concluded that the individual did not traverse
high dose rate areas.
I
I
Prior to the conclusion of the inspection, on February 4,1982,
!
the licensee had taken corrective action and the area was
adequately locked.
The above item is a third example of violation of Technical
l
Specification 6.13.1 requirements.
]
e.
Use of Continuously Indicating Dose Rate Instrument in
l
1
i
On February 1,1982 a licensee's contractor supervisor entered
~
a High Radiation Area by unauthorized means (details in
paragraphs 6.b and 6.d).
The individual had signed on RWP
,
No.10741 which established the highest dose rate in the area
4
at 160 mrem /hr.
The RWP did not specify that a radiation
monitoring device which continuosuly indicates the dose rate
.
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-17-
in the area was to be used, and the individual entered the
High Radiation Area without using such an instrument.
i
The above item is a fourth example of violation of Technical Specification 6.13.1 requirements.
f.
Timely Corrective Action of Identified Deficiency
At the meeting held on January 28, 1982 with licensee repre-
sentatives, the licensee was informed that the failure to
ensure administrative control of the "D"
ring door constituted
an apparent violation of Technical Specification 6.13.1.
Licensee representatives stated that the door was locked, and
that an individual could only enter the area by intentionally
violating established procedures.
On February 1,1982 a licensee Radiological Controls Technician
observed and reported that an individual entered the
"D"
ring
,
,
area by the unauthorized means brought to the licensee's
i
attention on January 22, 1982, and again on January 28, 1982.
On February 3,1982, the inspector observed that the door
still was not locked to prevent unauthorized entry and identified
y
this continuing violation to licensee management.
On February 4,1982 the
"D" ring door was adequately locked by
the licensee.
Section 6 of the QA Plan designates radiation control activities
as important to safety.
Section 8.1 of the Plan discusses
measures to insure deficiencies and noncompliances in quality
be promptly identified and corrected.
The quality concept
discussed in the QA Plan includes radiation control area
activities.
g.
Findings
(1) At the conclusion of the inspection, the inspector stated that
the items identified in paragraphs 6.b, 6.c, 6.d and 6 e
constitute an apparent violation of the regulatory requirements
of Technical Specifications Section 6.13.1 (289/82-01-01).
(2)
During the exit interview, the inspector stated that
failure to immediately provide the RB "D" ring door with
a lock to prevent unauthorized entry or to immediately
provide acceptable alternative interim positive control
for the High Radiation Area door, after the apparent
violation of Technicial Specification 6.13.1 had been
identified on January 22, 1982, constituted an apparent
violation of Section 8.0 of the TMI-l Operational Quality
Assurance Plan, Revision 9, dated May 28, 1981 (289/82-01-02).
.
.
.
-18-
(3) On February 11, 1982, the inspector discussed with the
Vice President and Director TMI-l the problems and
inadequacies related to the radiological controls of High
Radiation Areas.
The Vice President and Director TMI-l
stated that a full review of the radiological controls of
High Radiation Areas will be conducted.
The licensee's
review of this matter will be examined during a subse-
quent inspection (289/82-01-03).
7.
TMI-l Restart Modi f_ications
a.
General
The inspector reviewed selected facility modifications (listed
below) which are required to be completed prior to TMI-l
restart to verify that the new designs are provided consistent
with the following items.
--
licensee commitments stated in the TMI-l restart report
" Report in Response to NRC Staff - Recommended Requirements
for Restart of Three Mile Island Nuclear Station Unit 1"
requirements delineated in NUREG-0680 (and supplements),
--
"TMI-l Restart Evaluation Report", to comply with NRC
Commission Order of August 9,1979
--
industry codes and standards to which the facility was
constructed (or as approved by NRR)
--
applicable regulatory guides
the licensee's QA program
--
--
applicable licensee procedures for modification design,
procurement, installation, and construction testing
For each of the listed modifications the inspector verified
that the modification task was installed in accordance with
the approved design based upon observation of completed work,
review of related portions of the licensee's Quality Assurance
(QA) program, examination of installation records, review of
nondestructive examination (NDE) and/or other inspection
records, and other related documentation.
Specific modification
task observations and records reviewed by the inspector are
identified below.
,
b.
Modification Task RM-13A/E, Emergency Feedwater (EFW) Auto
j
S_ tart (Safety Grade)
)
)
,
_ _ ___
-.
. -
- -__
-
.
-19-
4
(1 ) Re ferences
--
TMI-l Restart Report Sections 2.1.1. 7 ; 2.1.2.6 ;
Supp.1 Part 1 Questions 1-1 , 54, 58; and Supp. 1
Part 3 Question 4
NUREG-0680 Items Short Term la-1, Auto Initiation of
-
i
EFW; Short Term la-3, Auto EFW Load on Diesels; and
8-2.1.7.a , EFW Auto Initiation
t
(2) Modification Description
i
Task RM-13A/E provided the motor-driven emergency feedwater
pumps (EFP's) with automatic start signals on loss of all
four reactor coolant pumps (RCP's) or loss of both main
This was accomplished by utilizing
,
'
contacts from the RCP power monitors and by sensing the
'
differential pressure across the MFP's.
The actuation
system consists of two trains with each train containing
two differential pressure switches to sense loss of MFP's
-
(one for each pump) and four contacts from the RCP power
'
monitors (one for each pump).
The motor-driven EFP's
4
!
will automatically load on the diesel generators during
1
The plant configuration changes associated with Task RM-13A/E
included installation of upgraded pressure switches to
,
i
sense MFP differential pressure, actuation circuit components
)
(autuation relays, contactors, time delay relays) ccnduit/ conduit
~
j
supports / electrical cable and instrument tubing / tubing
i
supports.
,
(3) Documentation Reviewed /0bservations
i
1
'
,
The inspector reviewed the following documentation related
to task RM-13A/E.
4
!
'
--
System Design Description (SDD) 424A, Revison 1,
Engineering Change Modification (ECM) S-021, Revisons
--
'
(Rev.) 0-2, Electrical I&C-Auto Start of EFW Pumps
EF-P2A/2B (Control Grade)
-
ECM S-076, Revs. 0-9, Electrical /I&C-Auto Start of
'
--
EFW Pumps (Safety Grade)
Purchase requisitions / orders
--
i
Cable pull / termination sheets
--
4
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i
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y,ym,ry,-y,y,,p--v- - -
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Work authorization notices
-
QC inspection reports
--
3
--
Design change notices for design verification
!
Installation drawings and "as-built" piping and
--
instrumentation drawings
,
1
i
--
Construction test data associated with Test Procedure
(TP) 250/1 Instrumentation Test, TP 250/2 Electrical
Test, TP 250/2.1 Control Logic Test for Breaker ID3,
and TP 250/2.2 Control Logic Test for Breaker IES
i
'
--
GPUNC Modification Turnover Packages Nos 021-1,
accepted October 2,1981 and 076-1, accepted November 18, 1981
2
In addition to the above documentation review, the inspector
4
'
conducted a system walkdown of the plant modifications
associated with Task RM-13A/E.
The inspector observed
the installed equipment and verified the component location,
i
1
i
'
and installation was as described in the applicable
.
modification documentation.
i
(4)
Fi ndings_
(a) Based on the modification documents reviewed by the
inspector and the observation of installed equipment
and components, the inspector determined that
Task RM-13A/E was satisfactorily completed in conformance
'
with the above referenced commitments and requirements,
except as described in paragraph 7.b.(4)(b).
I
(b)
There is one significant incomplete work list item (WLI)
1
i
related to Task RM-13A/E, ECM S-076 (WLI#4, DCN-DT-0465 R0
test switch) which requires completion prior to TMI-l
restart.
This item will be reviewed during a subsequent
inspection (289/82-01-04),
c.
Modification Tasks RM-13A Backup _ Instrument Air System and
RM-13C Emergency Feedvater Cont _rol Valves
" Fail Open"
(1 )
Re ferences
i
'
__
--
TMI-l Restart Report Section 2.1.1.7
NUREG-0680 Item Short Term la-2, EFW valves fail
--
open
!
.
l
4
,
._
-
_
, _ _ . _
. . . _ . _ . _ . _ _ _ _ _ _ . , _ _ - . _ _ _ _ , . _ ,
_ . . -
.
_ _ _ , . _
_ _ _ _ _ - _ _ -
.
.
- 21 -
(2) Modification Description
Task RM-13A added two backup emergency sources of instrument
air to control selected feedwater, emergency feedwater
and main steam valves and equipment.
For each backup air
source the air supply is received from an 80 gallon
reservoir which is supplied by a 5 hp,18 SCFM air compressor,
Ingersoll-Rand Type 30.
Transfer to the backup air
supply is automatic and no operator action is required.
On air system pressure dropping below 70 psig the supply
line from the backup air compressor is opened.
This is
accomplished by a Fisher 122R (air to close, fail open)
valve actuated by a Fisher 168H snap acting pneumatic
switching valve that senses the instrument air (IA) header
pressure.
One backup air source supplies equipment in
the intermediate building.
The other air source supplies
equipment in the turbine building.
Task RM-13C changed the failure mode of emergency feedwater
control valves EF-V30A/B to provide further assurance
that emergency feedwater can be delivered when required.
Previously these valves failed half open on loss of
control power and failed "as-is" on loss of instrument
air.
The change consists of modification to the operator
such that on loss of air the valves will fail in the open
position and remain in this position.
The change was accomplished using a Fisher 476U accessory
trip mounting package, FS476-U-20.
The plant configuation changes associated with Tasks RM-13A
and RM-13C included addition of equipment described above
plus electrical cable, conduit / conduit supports, various
electrical components, piping / pipe hangers, and check
valves.
(3)
Documentation Reviewed /0bservations
The inspector reviewed' the following documentation related
to tasks RM-13A and RM-13C.
System Design Description (SDD) 424A, Revision 1,
-
--
Engineering Change Modification (ECM) S-001, Revisions
(Rev.) O and 1, Mechanical /I&C - Install backup I A
l
compressors and tubing for selected plant valves
ECM S-008, Rev. O, Electrical - Install circuits
--
from IB/IA ES 480V Switchgear - install grounding
_ _ _ _ _
_ _ _ -
______ _ _ - _
.
_
. ._
_
_ .
.
.
-22-
ECM S-005, Revs. 0-2, Mechanical - Modify EF-V30A/B
-
to fail open on loss of normal air supply
Purchase requisitions / orders
--
QC inspection reports
--
l
--
Work authorization notices
Field questionnaires
--
--
Design change notices for design verification
j
--
Installation drawings and "as-built" piping and
instrumentation drawings
--
Construction test data associated with Test Procedure
(TP) 250/1 Instrumentation Test, TP 250/2 Electrical
Test, TP 250/2.1 IA-P2B Control Logic Test, TP 250/2.2
IA-P2A Control Logic Test, TP 250/3 Hydro, TP 250/4
l
Flush, and TP 250/5 Mechanical Test
--
GPUNC Modification Turnover Packages Nos. 001-1 and
j
008-1 accepted December 18,1981 and 005-1 accepted
l
October 25, 1981
1
In addition to the above documentation review, the inspector
conducted a system walkdown of the plant modifications
associated with Tasks RM-13A and RM-13C.
The inspector
observed the installed equipment and verified the component
location and installation was as described in the applicable
modification documentation.
(4)
Findings
(a) Based on the modification documents reviewed by the
inspector and the observation of installed equipment
and components, the inspector determined that
Tasks RM-13A and RM-13C were satisfactorily completed
in conformance with the above referenced commitments
and requirements.
(b)
There are no significant incomplete work list items
related to Tasks RM-13A and RM-13C, which require
correction prior to TMI-l restart.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
l
-23-
d.
Modification Task RM-13G, Emergency Feedwater Control Room
Annunciator Panel
(1)
References
TMI-l Restart Report Sections 2.1.1.7 and Supp.1
--
Part 2 Question 6
flVREG-0680 Item Short Term la-8, EFW auto start
--
annunciate
(2) Modification Des _cription
Task RM-13G provided control rcom annunciation for all
auto start conditions of the emergency feedwater system.
The plant configuration changes associated with Task RM-13G
included addition of electrical cable, conduit / conduit
supports, terminal boxes, connectors, annunciator light
boxes and push button switches.
(3)
Documentation Reviewed /0bservations
The inspector reviewed the following documentation related
to task RM-13G.
System Design Description (SDD) 424A, Revision 1,
--
--
Engineering Change Modification (ECM) S-126, Revisions 0
and 1, I&C - Add new satellite annunciator light box
and wire to junction box
--
Purchase requisitions / orders
Cable pull / termination sheets
--
--
QC inspection reports
Work authorization notices
--
--
Field questionnaires
--
Design change notices for design verification
--
Installation drawings and "as-built" piping and
instrumentation drawings
Construction test data associated with Test Procedure
--
(TP) 250/2 Electrical Test
_ _ _ _
.
.
-24-
'
GPUNC Modification Turnover Package No.126-1
--
accepted June 4,1981
In addition to the above documentation review, the inspector
conducted a system walkdown of the plant modifications
4
associated with Task RM-13G.
The inspector observed the
installed equipment and verified the component location
and installation was as described in the applicable
modification documentation.
4
(4)
Findings
(a) Based on the modification documents reviewed by the
inspector and the observation of installed equipment
i
and components, the inspector determined that Task RM-13G
i
was satisfactorily completed in conformance with the
above referenced commitments and requirements.
(b)
There are no significant incomplete work list items
related to Task RM-13G, which require correction
I
prior to TMI-l restart.
e.
Modification Task RM-13H, EFW Turbine Safety Valves Lift
Setpoints*
(1) Re ference
--
NUREG-0680 Item la-Add'l 6, EFW Initiation Independent
of AC [ Power]
(2) Modification Description
Task RM-13H reduced the lift setpoints of the emergency
feedwater pump turbine safety valves from 495 and 505 psig
to 200 and 220 psig.
Task RM-13H also added a main steam
rupture restraint to protect the emergency feedwater
<
piping between the turbine driven emergency feedwater
pump EF-Pl A and the emergency feedwater manifold.
The plant configuration changes associated with Task RM-13H
included replacement of the safety valve springs and
.
j
addition of a main steam piping restraint.
l
- Another licensee modification task is also designated RM-13H.
That
task provides a two hour backup air supply for main steam and emergency
feedwater centrols.
The modifications associated with that task are
,
!
incomplete and will be reviewed during a subsequent inspection.
1
!
1
- - - ---
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.
____ ____--_____ _____ _
.
.
.
-
-25-
(3)
Docum atation Reviewed /0bservations
l
The inspector reviewed the following documentation related
to task RM-13H.
--
Engineering Change Modification (ECM) S-151, Revisions
(Rev.) 0 and 1, Mechanical - Install new springs in
valves MS-V22A/B
ECM S-198, Rev. O, Mechanical- Install main steam
--
rupture restraint
Purchase requisitions / orders
-
Work authorization notices
--
--
Design change notices for design verification
--
Installation drawings and "as-built" piping and
instrumentation drawings
--
GPUNC ttodification Turnover Packages Nos.151-1
accepted October 14,1981 and 198-1 accepted November 18, 1981
In addition to the above documentation review, the inspector
conducted a system walkdown of the plant modifications
associated with Task RM-13H.
The inspector observed the
installed equipment and verified the component location
and installation was as described in the applicable
modification documentation.
(4)
Findings
(a) Based on the modification documents reviewed by the
inspector and the observation of installed equipment
and components, the inspector determined that Task RM-13H
(ECM's S-151 and S-198) was satisfactorily completed
in conformance with the above referenced commitments
and requirements.
(b)
There are no significant incomplete work list items
related to this part of Task RM-13H, which require
correction prior to TMI-l restart.
f.
Modification Task RM-13I, Condensate Storage Tank Low Level
Alarm
(1)
Re ferences
TMI-l Restart Report Sections Supp.1 Part 1 Question 10a
--
and Supp.1 Part 2 Question 13
NUREG-0680 Item la-Add'l 1, Redundant Instrumentation
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(2) Modification Description
Task RM-13I provides each condensate storage tank with a
low-low level alarm.
The setpoint for each alarm is
5 feet + 0.2 feet.
The low-low level alarm is added to
alert tee operator that 20 minutes remain before the tank
is empty.
The operator would then have time to realign
the emergency feedwater pump (s) to an alternate water
source.
Task RM-131 also added a level gage (0-40 feet
range) mounted local to each tank to provide tank water
level indication.
The plant configuration changes associated with Task RM-13I
included installation of cable (between existing instrumentation
alarm module contacts and a termination box pre-wired to
the annunciator box in the control room), electrical
hardware and a new local level gage and isolation valve
(connected to existing instrumentation pipe).
(3)
Documentation Reviewed / Observations
The inspector reviewed the following documentation related
to task RM-131.
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System Design Description (SDD) 424-D, Revision 0,
Low-Low Level Alarm for Condensate Storage Tanks
Engineering Change Modification (ECM) S-203, Revision 0,
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Electrical - Provide alarm annunciation on existing
control room annunciator, an alarm message on the
plant computer and local indication for condensate
storage tanks CD-TI A and C0-TlB.
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Purchase requisitions / orders
Cable pull / termination sheet
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QC Inspection report
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Work authorization notice
Installation procedures
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Installation drawings and "as-buil t" piping and
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instrumentation drawings
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Construction test data associated with Test Procedure
(TP) 250/1 Instrumentation Test and TP 250/2 Electrical
Test
GPUNC Modification Turnover Package No. 203-1 (not
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accepted)
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In addition to the above documentation review, the inspector
conducted a system walkdown of the plant modifications
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associated with Task RM-13I.
The inspector observed the
installed equipment and verified the component location
and installation was as described in the applicable
modification documentation.
(4)
Findings
(a) Based on the modification documents reviewed by the
inspector and the cbservation of installed equipment
and components, the inspector determined that Task RM-13I
was satisfactorily complet'_u in conformance with the
above referenced commitments and requirements,
except as described below.
FCR C-599, Rev. O issued January 5,1982 requires
heat tracing of the new local level gages, PI-1004
and PI-1005.
The instrument line for PI-1004 requires
rerouting so heat trace cable can be installed.
Completion of the heat tracing required by FCR C-599
will be reviewed during a subsequent inspection
(289/82-01-05).
(b)
There are no significant incomplete work list items
related to Task RM-13I, which require correction
prior to TMI-l restart.
8.
TMI-l Restart Preoperational Testing
a.
Overall Preoperational Test Program
The inspector reviewed the overall preoperational testing
program for TMI-l restart with the Manager Startup and Test
TMI-l and the Supervisor Startup and Test TMI-l to determine
completion status of test procedure preparation, test performance
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and test results evaluation.
The licensee representatives
discussed some of the problems and discrepancies identified by
startup and test personnel during preoperational equipment
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calibrations and functional tests recently completed or in
progress.
The inspector noted that several preoperational
test procedures had been approved since the last inspection of
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this area and that some additional preoperational testing had
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been completed.
The scope and findings of the inspector's
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review of these items is described below.
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b.
Preoperational Test Procedu_r_e Review
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(1) General
The inspector reviewed selected calibration / functional
test procedures, related to facility modifications (listed
below) which are required to be completed prior to TMI-l
restart, to verify that adequate testing would be provided
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consistent with the following items.
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licensee commitments stated in the TMI-l restart
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report " Report in Response to NRC Staff - Recommended
Requirements for Restart of Three liile Island Nuclear
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Station Unit 1"
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requirements delineated in NUREG-0680 (and supplements),
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"TMI-l Restart Evaluation Report," to comply with
NRC Commission Order of August 9,1979
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licensee commitments stated in the THI-l Restart
Test Planning Specification, Revision 0, dated
April 8,1981
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applicable regulatory guides
the licensee's QA program
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applicable licensee procedures for preoperational
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testing
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For each of the listed modifications the inspector verified
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that the modification task would be demonstrated acceptable
for restart operation by an appropriate calibration /
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functional test.
The inspector reviewed each test procedure
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for technical / administrative adequacy of management
review and approval, procedure format, test objectives
(clearly stated and met), prerequisites, environmental
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conditions, acceptance criteria, technical references,
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initial conditions, test performance documentation and
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verification, detailed instructions for performance of
test, recording details of condect of test, restoration
of system to normal after test, identification of personnel
conducting test and evaluating test data, and independent
verification of critical steps or parameters.
Specific
modification tasks, modification design and test references,
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and preoperational test procedures reviewed by the inspector
are identified below.
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(2) Modification Task LM-2 RCS Wide Range Temperature
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References
TMI-l Restart Report Section 2.1.1.6
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NUREG-0680 Item 8-2.1.3.b Inadequate Core Cooling
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TMI-l Restart Test Planning Specification, Revision 0
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The inspector reviewed Test Procedure (TP) 657/1, Revision 0,
"Non-Nuclear Instrumentation - Hot Operation and Calibration,"
approved August 24, 1981.
TP 657/l provides an appropriate
functional test of Task LM-2 by verification of accurate
operation of the extended range reactor coolant system
hot leg temperature measurement instruments, including
checks against other independent instruments measuring
temperature and collection of data at reactor coolant
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temperature plateaus between 140 F and 532 F.
(3) Modification Task LM-23 High Range Containment Monitoriag
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,Re fe rence_s_
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TMI-l Restart Report Section 2.1.2.1
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NUREG-0680 Item 8-2.1.8.b Radiation monitor range
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TMI-1 Restart Tes! Planning Specification, Revision 0
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System Design Description 661C Containment High
Range Radiation Monitor
The inspector reviewed TP 366/3, Revision 0, " Containment
Post-Accident High Range Radiation Monitors - Calibration,"
approved December 18, 1981.
TP 366/3 provides an appropriate
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monitor calibration and verifies operability of alarms
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associated with Task LM-23 containment high range gamma
monitors.
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(4) Modification Task RM-5B Reactor Building Isolation
on High Radiation
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Re ferences
TMI-l Restart Report Section 2.1.1.5
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NUREG-0680 Item 8-2.1.4 Containment isolation
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TMI-l Restart Tect Planning Specification
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System Design Description 642A Containment Isolation
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Modi fication
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The inspector reviewed TP 366/1, Revision 0, " Containment
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Isolation on High Radiation - Calibration," approved
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October 23,1981 and TP 366/2, Revision 0, " Containment
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Isolation on High Radiation - Valve Functional Test,"
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approved July 22, 1981.
TP 366/1 and TP 366/2 provide an
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appropriate calibration / functional test of Task RM-5B by
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calibration of containment isolation high range radiation
monitors, verification of functions of each channel,
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verification of closure of containment isolation valves,
verification of high radiation isolation signal bypass
functions, and verification of isolation valves remaining
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closed after the initiating signal has been reset.
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(5) Modification Task RM-13A Backup Instrument Air System
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Re ferences
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TMI-1 Restart Report Section 2.1.1.7
NUREG-0680 Item Short Term la-2 EFW valves fail open
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TMI-l Restart Test Planning Specification
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System Design Description 424A Emergency Feedwater
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System
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The inspector reviewed TP 248/1, Revision 0, " Backup
Instrument Air Functional Test," approved December 18, 1981.
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TP 248/l provides an appropriate functional test of
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Task RM-13A by verifying operability of the backup
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instrument air compressors, proper operation of block
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valves and switching valves and individual component
operation by the backup instrument air system.
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(6) Modification Task RM-13A/E Emergency Feedwater Auto Start
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References
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TMI-l Restart Report Sections 2.1.1.3, 2.1.1.7, 9.2,
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and Supp.1 Part 1 Question 3
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NUREG-0680 Item Short Term la-3 Auto EFW load on
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diesel s
TMI-l Restart Test Planning Specification
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System Design Description 424A Emergency Feedwater
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System
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The inspector reviewed TP 622/1, Revision 0, " Diesel
Generator Load Test," approved September 4,1981.
TP 622/1
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provides an appropriate functional test of Task RM-13A/E
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with respect to automatic loading of the motor-driven
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emergency feedwater pumps on the diesel generators.
The
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test ensures the engineered safeguards electrical system
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(diesel generators on loss of offsite power) has the
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capability and sufficient capacity to accept required
loads including new loads such as the emergency feedwater
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pumps and pressurizer heaters,
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(7) Modification Task RM-16 Pressurizer Heater Emergency Power
Re ferences
TMI-l Restart Report Sections 2.1.1.3 and Supp.1
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Part 2 Question 30
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NUREG-0680 Item 8-2.1.1 Emergency Power Supply
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TMI-l Restart Test Planning Specification
System Design Description 902A Pressurizer Heater
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Emergency Power and Reliability Improvements
The inspector reviewed TP 427/2, Revision 0, " Pressurizer
Heater Emergency Power Functional Test,"' approved ' December 18, 1981.
TP 427/2 provides an appropriate functional test of Task RM-16
by verifying transfer of pressurizer heaters power from a
non-emergency safeguards (ES) power supply to an ES power
supply within two hours and ability to transfer back to-
the non-ES power supply.
(8)
Findings
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The inspector determined ~ that each of the preoperational
test procedures was technically and administratively
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adequate. No discrepancies were noted in the review of
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these procedures.
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9.
TMI-l Restart Overall Startup Test Program
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The inspector conducted the initial onsite review of the THI-1
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restart startup test program for criticality and low power physics
tests during this inspection period.
The inspector discussed the
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startup test program with licensee personnel and reviewed test
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program documents to determine the following items.
Tests to be performed have been identified and sequenced.
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Each of the identified tests is provided with detailed written
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procedures.
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The test program includes applicable licensee cosmitments for
startup testing,
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Administrative measures have been established govbrning the
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conduct of testing.
The inspector reviewed a draft copy of the startup sequencing
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schedule and verified that TMI-l restart preoperational. testing
discrepancies and problem areas related to required modifications
and non-modified systems'were identified and subsequent retest
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items were sequenced during low power physics testing; that initial
criticality and low power physics tests were properly sequenced;
and that natural circulation tests were scheduled prior to power
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escalation tests.
The inspecto" determined that the low power physics testing program
includes tests for critical boron concentration, control rod exercise,
nuclear instrumentation (NI) operation, temperature coefficients,
rod worth, ejected rod worth, and shutdown margin demonstration.
The inspector reviewed Test Procedure 700/2, " Low Power Natural
Circulation Test" (Draft) and verified that the following tests
4
were scheduled.
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Emergency feedwater actuation upon loss of both main feedwater
pumps
Natural circulation upon loss of forced circulation
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Natural circulation with manual control of 0TSG water level in
the event of loss of integrated control system (ICS) control
Natural circulation with loss of pressurizer heaters
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Natural circulation at reduced pressure
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Natural circulation following the loss of normal and backup
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instrument air
The licensee provided the inspector with eight draft test procedures
and two approved test procedures related to the startup test program
low powcc testing and power escalation testing phases.
The inspector
also received operating and surveillance procedures associated with
startup testing.
These procedures will be reviewed during a subsequent
NRC inspection.
Based on the discussions with licensee personnel and documents reviewed
during this initial inspection, the inspector determined that the test
program appears adequate for TMI-l restart startup testing.
Other aspects of the overall startup test program, including test
organization, test program administration, document control and
test and measurement equipment, will be reviewed dur.ing a subsequent
NRC inspection.
10
Unresolved Items
Unresolved items are matters about which more information is required
in order to ascertain whether they are acceptable items, items of
noncompliance, or deviations.
An unresolved item disclosed during
the inspection is discussed in paragraph 6.
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11.
ExitIntervieh
Meetings were held with senior ficility management periodically
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during the course af the inspect on to-discuss ~the. inspection scope
and findings.
The Inspectors me eith the licensee representativas
(denoted in paragraph 1) at the cu tclusion c.f the inspection on
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February 16, 1982, and sur.narized the purpose and scope of tne
inspection and the findings.
The licensee representatives acknowledged
the findings.
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