ML20137W537

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Safety Insp Rept 50-289/85-30 on 851213-860110.Violation Noted:Failure to Coordinate Surveillance Procedure Re Daily Checks of Fire Door.Problems Also Noted in Mgt & Technical Support Staff Review of Plant Deficiencies
ML20137W537
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 02/12/1986
From: Conte R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20137W515 List:
References
50-289-85-30, NUDOCS 8602200204
Download: ML20137W537 (89)


See also: IR 05000289/1985030

Text

{{#Wiki_filter:U.S. NUCLEAR REGULATORY COMMISSION

                                         REGION I
  Report No.               50-289/S5-30
 Docket No.                50-289
  License No.              DPR-50             Priority --         Category C
  Licensee:                GPU Nuclear Corporation
                           Post Office Box 480
                           Middletown, Pennsylvania    17057
 Facility At:              Three Mile Island Nuclear Station, Unit No. 1
 Inspection At:            Middletown, Pennsylvania
 Inspection Conducted:     December 13  u 1935 - January 10, 1986
 Inspectors:               W. Baunack, Project Engineer, Region I
                           N. Blumoerg, Lead Reactor Engineer, Region I
                           L. Briggs, Lead Reactor Engineer, Region I
                           J. Bryant, Senior Resident Inspector (0conee),
                              Region II
                           P. Eapen, Chief, Quality Assurance Section, Region I
                           D. Haverkamp, Technical Assistant for TMI-1 Restart,
                              Region I
                          W. Oliveira, Reactor Engineer, Region I
                           D. Tricole, Resicent Inspector (Calvert Clif R)
                              Region I
                           R. Urban, Reactor Engineer, Region I
                          A. Weacock, Radiation Specialist, Region I
                           P. Wen, Reactor Engineer, Region I
                          J. White, Senior Radiation Specialist, Region I
                           F. Young, Resident Inspector (TMI-1), Region I
 Other NRC Personnel:     J. Thoma, Project Manager, Office of Nuclear Reactor
                              Regulation
 Contractor Personnel:    B. Gore, Senior Research Scientist, Battelle Pacific
                             Northwest Laboratories
 Approved By:           h           J
                       O R. Conte (A M) _-1 Restart Manager
                                                                           2/fkd
                                                                            Date
                           TMI-1 Restart Staff
                          Division of Reactor Projects
 Inspection Summary:
 The TMI-1 Restart Staff conducted routine and special (NRC shift coverage)
 safety inspections (838 hours) of power operation focusing on operator and

!

                                s
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                                 .-                  ._ -                    _               - .  -               .               __
                                                                 2
:
    management performance.                      Specifically, items reviewed in more detail in the
     facility operations area were: control of fire doors; power operated relief
     valve test results; pressure switch malfunction for makeup pump lube oil
     sub-system, diesel generator standby coolant system; letdown cooler leakage;
    out-of-specification log entries; instrumentation monitoring; and annunciator
    black board conditions. Special focus continued on the ccmpletion of the
    power escalation testing program, the radiation protection program as applied
    to power escalation, and the non-licensed training program. Other review
:    items included: reactor trip event and post-trip review; radiological release

i

    events; emergency feedwater pump operability; licensee readiness for continued
    power operations; steam generator cleaning techniqua; and licensee action on
    previous inspection findings.
     Inspection Results:

,

    Licensee management and the quality assurance department continued their
   presence and involvement in daily activities.                               Problems were noted in the
   thoroughness and completeness of management and technical support personnel
    review of plant problems. The problem of workers in the spaces having the
   potential to cause safety system challenges persisted. Apparently the
    licensee's corrective actions are not yet understood by all workers. The
    licensee continued to be aggressive in the maintenance of safety-related
   equipment.
  Operators continued to conduct themselves in a competent manner and their
   actions reflected a strong performance-oriented training program. Accordingly,

, operators were responsive to radiological esents and plant trips that occurred

  during this period. A poor operational practice was noted of "living with"
   out-of-specification readings; although operator log-keeping actions were

, appropriate, it appeared that mid-level managers were unresponsive in taking

  corrective actions. No performance problems were identified in the review of
  non-licensed operator training. Overall, procedures were properly implemented,
  but individual procedure step inadequacies continued to be observed. The
   labeling on fire doors was confusing. An improperly coordinated surveillance
  procedure change with respect to daily functional checks of fire doors resulted
   in an apparent violation of technical specifications (paragraph 3.2.2).
  The startup test program was effective in identifying system interface
  problems and in providing training for plant operators along with carfirming
  proper plant performance.
  The Radiation Protection Program remained strong in support of licensee work
  activities during the power operation mode. Personnel inattentiveness was the
  cause for radiation area signs being left down; and, as a result in one case,
  an individual entered a high radiation area without knowing it.                                No overexposure
  occurred.
  The licensee was responsive and took appropriate corrective action for NRC staff
  findings from previous inspections.
  The return to commercial power operations was conducted in a deliberate and
  conservative manner.
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                                                                                _ _ . _ . _ _ . . _               _ . -   ..                 ..
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                                                                                                                        3
                                                                                                                    DETAILS
                      1. Introduction and Overview
                         1.1 General

>

                              At the beginning of this inspection period on December 13, 1985, the
                               TMI-1 Restart Staff was providing on-shift inspection coverage 12
                               hours a day to assess restart operating activities. At 3:00 a.m. on
                              December 27, 1935, continuous coverage was initiated for the power
                              escalation to the maximum achievable power testing plateau, and at

'

                              6:00 p.m. on that day this inspection coverage was returned to 12
                              hours a day consistent with the reduced level of testing activity and
                               steady-state facility operation.

I

                              On both Christmas and New Year's Day periodic inspection coverage was
                              provided by the resident inspectors. At 7:00 a.m. on January 2, 1986,
                              continuous coverage was again initiated for a planned reactor trip

$.

                              test from maximum achievable power and the subsequent plant restart.
                              Shift coverage was terminated at 7:00 a.m. on January 5, 1986, follow-
                              ing the return to steady-state plant operation at 90% of rated power,
                              marking the completion of the restart test program. As of 8:00 a.m.
                              on January 10, 1986, the TMI-1 Restart Staff organization was secured
                              and TMI-1 inspection responsibility was returned to the normal Region I
                              organization alignment.

! The staff's on-shift observation of plant activities was maintained

                              by NRC personnel from Regions I and II and by a reactor operator ex-
                              aminer from an NRC contractor. Also, Region I inspectors conducted a
                              review of non-licensed personnel training and continued periodic
                              coverage of testing and radiation protection activities. Additional

i Region I personnel were on site during portions of the period to

                              augment the resident inspection staff.
                         1.2 Facility Restart Operations
                              During the period of December 13, 1985 to January 10, 1986, the sig-
                              nificant TMI-1 restart operational milestones included:                                                             (1) power

! escalation and main turbine generator operation and turbine runback

                              test at the maximum achievable power testing plateau, (2) turbine
                              trip / reactor trip from maximum achievable power, and (3) return to

j power operation, marking the completion of the restart test program.

                              Subsequently, the plant was able to achieve operation at 100% of rat-
                              ed power and additional full power test data were taken.                                                             The chrono-

j logical summary of plant operations during the period is presented l below.

1
I
                                                                                                                                                                 .
  ---_
       ,e --- _ _ _ -     y-. , . . _ _ , _ _ - - . _ _ _ . - - . - . - - - - - ~ . . - - - .
                                                     -
                                                                                                    . . - . . - - - - -      - _ . - . --. _    _         - -  -
  - _ _ - .         .             . .      .                        -           . - - _ _
                                      4
            Date       Time             Operational Highlight or Milestone
            12/13/85   7:00 a.m.        Reactor at 75% of rated power
            12/27/85   4:16 a.m.        Region I Administrator authorized the

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;                                       licensee to escalate power to the maxi-
                                       mum achievable power plateau
                      4:20 a.m. -       Increased power to 87.5% at 3% per
                        8:55 a.m.       hour; power escalation stopped when
                                       approaching the once through steam gen-
                                       erator operating level limits

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                       1:37 p.m. --    Conducted loss of main feedwater pump
                        1:50 p.m.      runback test from 87.5% of rated power
                                       and returned power to 87.5%
            1/2/86    12:04 p.m.       Conducted turbine trip / reactor trip
                                       test from 88% of rated power
                      1:10 p.m.        Tripped reactor coolant pumps for
                                       emergency feedwater system initiation
                                       testing
                      1:17 p.m. -      Reactor coolant pumps restarted,
                        1:37 p.m.      providing forced circulation flow
            1/3/86    10:28 p.m.       Region I Administrator authorized the
                                       licensee to return to power operations
                      10:29 p.m.       Commenced control rod withdrawal for
                                       reactor startup
                      10:55 p.m.       Reactor critical
            1/4/86    3:26 a.m.       Main turbine generator connected to
                                       regional electrical grid
                      3:43 a.m.       Reactor trip due to turbine trip caused
                                      by high level in moisture separator IC
                      11:09 a.m.      Commenced control rod withdrawal for
                                       reactor startup
                      11:56 a.m.      Reactor critical
                      2:15 p.m.       Main turbine generator connected to
                                      regional electrical grid
                      10:00 p.m.      Reactor at 90% of rated power
                                      5
      Date             Time             Operational Highlight or Milestone
      1/5/86           7:00 a.m.        Reactor at 91% of rated power, secured
                                        on-shift inspection coverage
      1/6/86           2:05 p.m.        Reactor at 100% of rated power
      1/10/86          4:00 a.m.        Reactor power reduced to 75% in order
                                        to take a main feedwater pump out of
                                        service to assess high pump vibrations

1.3 Operational Events

     Several events or other matters occurred during this inspection peri-
     od that were considered either operationally significant or of spe-
     cial interest to the TMI-1 Restart Staff.         These items are discussed
     below.
     On December 17, 1935, a contamination event occurred when noble gas
     was released into the auxiliary building atmosphere during replace-
     ment of a waste gas compressor filter.        All workers leaving the
     building were frisked by health physics technicians.         Seven workers
     and one region-based NRC inspector were slightly contaminated. In
     the case of the NRC inspector, only his hard hat was contaminated.
     The licensee estimated personnel exposures of about 4E-4 millirem
     from the contamination.
     On December 30, 1955 at 1:50 a.m., the licensee declared an unusual
     event condition due to a release of noble gas monitored by the plant
     effluent monitor. The unplanned release was due to failure of a
    makeup pump (high pressure injection pump) shaft seal. Although the
     plant effluent monitor went below the alert level at approximately
     2:30 a.m., the licensee decided to stay in the unusual event condition
     until the affected pump was drained and isolated.         The licensee
     secured from the unusual event at 4:20 a.m.
    During power ascension on January 5, 1986, following the reactor
     trips that occurred on January 2 and 4,1986, steam generator level
    versus reactor power tracked lower than during the power escalation
    program in which maximum achievable power was 88%, due to high opera-
     ;ing water level in the steam generators.         The licensee attributed
     the change to a redeposition of fouling material in the steam gener-
    ators. Consequently, the plant was able to achieve full power opera-
  ' tion on January 6,1986, with steam generator water levels well
    within operational limits. Subsequently, the licensee conducted full
    power tests that were deferred because of the previous power
     limitations.    Startup testing was completed on January 9, 1986.
    Reactor physics testing was completed by January 16, 1986.
                                              ,
                                        6
  1.4 Summary
        This inspection included restart testing activities for portions of
        the 75'; and maximum achievable power plateaus, and subsequent plant
        operations at 100*o of rated power. During this period there were no
         interruptions of the restart testing program due to equipment prob-
         lems or for other reasons. However, an unplanned reactor trip de-
         layed the plant startup, following a planned reactor trip from
        maximum achievable power, for several hours. The shift inspectors
        referred only implementation matters or status questions to shift
        supervisory personnel and referred programmatic matters (event
        followup, design or procedure adequacy problems) to resident and
        region-based NRC personnel.     Resident and region-based personnel in-
        terfaced with licensee support groups in followup to shift inspector
        referrals / concerns. The staff's observations and findings regarding
        plant operations and testing and licensee response to operational
        events is discussed in the report sections that follow.

2. Shift Insoection Activities

  2.1 Scope of Review and Observations
        During the period of December 13, 1935 - January 5, 1986, the TMI-1
        Restart Staff continued its augmented shift inspection coverage. The
       NRC shift inspectors assessed the adequacy and effectiveness of
        operating personnel performance based on the inspectors' observations
       of operating and startup activities to determine that:
       --
              operators are attentive and responsive to plant parameters
              and conditions;
       --
              plant evolutions and testing are planned and properly
              authorized;
       --
              procedures are used and folicwed as required by plant
              policy;
       --
              equipment status changes are appropriately documented and
              communicated to appropriate shift personnel;
       --
              the operating conditions of plant equipment are effectively
              monitored and appropriate corrective action is initiated
              when required;
       --
              backup instrumentation, measurements, and readings are used
              as appropriate when normal instrumentation is found to be
              defective or out of tolerance;
                                     _ _   . _ _ _          -

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                                   7
  --
        logkeeping is timely, accurate, and adequately reflects
       plant activities and status;
  --
       operators follow good operating practices in conducting
       plant operations; and
                                                                        l
  --
       operator actions are consistent with performance-oriented        {
       training.
                                                                        l
 The shift inspectors' observations included, but were not limited to,
  those reactor plant operation and startup testing activities, period-
  ic surveillance and maintenance testing activities, and preventive
 and corrective maintenance activities listed below.
  Reactor Plant Operation and Startup Testing Activities
 --
       routine control room operations including annunciator alarm
       response and control room logkeeping
 --
       operating and emergency procedures discussions with shift
       supervisors, shift foremen, control room operators and
       shift technical advisors
 --
       periodic inspection observation tours of areas outside the
       control room, including diesel generator rooms, emergency
       feedwater rooms, control building, turbine building, auxil-
       iary building, intermediate building, electrical switchgear
       rooms, and outside buildings and yard areas
 --
       routine operations and maintenance planning briefings be-
       tween plant operations manager and shift supervisors
 --
       preparations for underwater inspection of a river water
       pump to verify proper lubrication connections

( ( --

       establishment and maintenance of cold weather protection

! controls

 --
       operating crew equipment tagging and lineup preparations
       for turbine-driven emergency feedwater pump 1A controller
       replacement
 --
       special shift crew briefings by the Vice President and
       Director of TMI-l regarding past performance and expected
       operating practices
 --
       shift crew actions in response to purge valve AH-V-113
       found to be leaking greater than prescribed limits during
       performance of surveillance procedure 1303-11.180
                 - _ _ - _ _ _ _ _
 _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ __ ______ __                      _
                                                                                                           8
                                                                             --
                                                                                operating crew response to spurious automatic start of
                                                                                makeup pump 1A auxiliary oil pump
                                                                             --
                                                                                shift crew assessment and critique of contamination inci-
                                                                                dent that occurred during waste gas system maintenance on           l
                                                                                December 18, 1985
                                                                             --
                                                                                operating personnel actions performed in makeup pump rooms
                                                                                during startup of makeup pump 1B and reciring of makeup
                                                                                pump 1A
                                                                            -
                                                                                operating crew changeover of letdown. coolers to investigate
                                                                                possible source of primary water leakage into intermediate
                                                                                closed cooling water system
                                                                            --
                                                                                operating crew preparations for post maintenance leak test-
                                                                                ing of neutralizer pump 1B seal replacement, performed in
                                                                                May 1985
                                                                            --
                                                                                operator response to control room annunciator alarms for
                                                                                " rods symmetrical" and " inhibit rod out motion" received
                                                                                twice in close succession
                                                                            --
                                                                                operating crew preparations for mechanical modification of
                                                                                letdown radiation monitor RM-L-1 flow controller
                                                                            --
                                                                                operating shift response to failed river water inlet tem-
                                                                                perature detector, assumed caused by river ice buildup
                                                                                tearing detector away

,

                                                                            --
                                                                                operating crew performance of power escalation from 75% to

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                                                                                87.5% of rated power at 3% per minute
                                                                            --
                                                                                operating crew and test personnel briefings for and perfor-
                                                                                mance of integrated control system tuning tests at 87.5% of
                                                                                rated power
                                                                            --
                                                                                operating crew and test personnel performance of turbine
                                                                                runback test on loss of main feedwater pump
                                                                            --
                                                                                power escalation to 90% of rated power when average coolant
                                                                                temperature was raised 5 degrees F for physics testing
                                                                            --
                                                                                shif t crew and test personnel briefings for and conduct of
                                                                                planned turbine trip / reactor trip on January 2, 1986
                                                                            --
                                                                                control room operator withdrawal of shutdown group rods
                                                                            --
                                                                                operating crew response to overheating pump for the
                                                                                hydrogen / oxygen analyzer
                                                                                                                      - _ _ _ _ _ _ _ _ _ _ _ _ _ _
                            _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _                           __
                                                                                                 -
                                                                                            9
     --
         operating crew preparations for plant startup following the

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         planned reactor trip
    --
         reference leg filling for OTSG 1A level transmitter for
         LT-3 and LT-5                                                                             l
    --
         control room operator withdrawal of safety group rods

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    --
         turbine generator startup

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    --
         operating crew response to unplanned turbine trip / reactor

.

 -
         trip on January 4, 1986

r

    --
         operating and engineering staff post-trip review of un-
         planned reactor trip
    --
         operating crew performance of reactor and turbine generator
         startup following unplanned reactor trip on January 4,1986

I --

         power escalation to 91% of rated power
    Periodic Surveillance and Maintenance Testing Activities
   --
         main feedwater pump testing per operations surveillance
         procedure OPS-5101
   --
         emergency feedwater pump 1A controller replacement
         post-maintenance testing
   --
         portions of reactor protection system surveillance
         activities
   --
         portions of control rod movement tests per surveillance
         procedure 1303-3.1
   --
         pressurizer power operated relief valve monthly surveil-
         lance testing per surveillance procedure 1303-11.45
   --
         portions of high and low pressure injection analog channels
         quarterly testing per surveillance procedure 1303-4.11
   --
         portions of area radiation monitors monthly calibration
         tests per surveillance procedure 1303-4.15C
   --
         fire system testing and flushing of deluge / sprinkler system
         per surveillance procedure 1303-12.13
   --
         main feedwater pump flow instrument calibration to trouble-
         shoot different transmitter indications at same feedsater
         flow location, per job ticket CI403, dated December 20,
         1985
                                                                    _ _ _ _ _ _ _ _ _ _ _ _
                                                .
                                                  10
                     --
                         post maintenance testing of new controller for
                         turbine-driven emergency feedwater pump 1A, using surveil-
                         lance procedure 1300-3G
                    --
                         portions of power range nuclear instrumentation calibration
                         per surveillance procedure 1302-1.1
                   --
                         portions of emergency feedwater pump flow testing per sur-
                         veillance procedure 1300-3G A/B and adjustments of valve
                         controller steam inlet pressure to various settings to as-
                         sure minimum pressure and flow design requirements are met
                   --
                        decay heat river water system weekly surveillance testing
                  --
                         special operability testing of letdown isolation valve
                        MU-V-3
                 --
                        control rod patch panel verification per surveillance pro-
                        cedure 1301-9.2
                 --
                        letdown isolation valve time delay relay testing
                 --
                        emergency feedwater pump 2A testing per surveillance proce-
                        dure 1300-3F
                 Preventive and Corrective Maintenance Activities
                 --
                        troubleshooting and repair of once through steam generator
                        IA level transmitters LT-3 and LT-5
                --
                        turbine-driven emergency feedwater pump 1A controller
                        replacement
                --
                        troubleshooting and investigation of makeup pump 1B lube
                        oil pressure switches
                --
                        temporary repairs to leaks in secondary system valves and
                        an emergency feedwater riser flange using Furmanite sealant
                --
                        repair of soldered hot spots in control room drive cabinet
                        per job ticket CI-231
                In addition, shift inspectors conducted or contributed to the follow-
                ing special reviews of facility design and operational matters or of
                the licensee's administrative controls programs.
               --
                        closure controls for fire doors
               --
                        hydrolazing (water spraying) of bu.lding spray / decay heat
                        vaults to reduce contamination and radiation levels
                                                             --~-        - -- ---

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                                                                                             _ _ .
                                                 11
             --
                       partial valve lineup verification for emergency feedwater
                       pumps
            --
                      control room computer alarm priority system
            --
                      operating crew response to out of tolerance secondary plant
                      equipment readings, while operating at 75% of rated power
            --
                      use of scaffolding for planned maintenance activities, such
                      as emergency feedwater pump 1A controller replacement
            --
                      worker use of piping and valves as footholds / support in

, lieu of ladders or scaffolding

            --
                      shift crew trending of reactor coolant system leakage
            --
                      barrier control practices for entrances to high radiation
                      areas
           --
                      effects of vent header pressure changes on reactor coolant
                      system leakage measurements
           --
                      trending of pressurizer power operated relief valve
                      setpoint check monthly surveillance procedure test results
                      for tests conducted since June 1985
           --
                      operating staff trending and followup to out-of-specification
                      readings for emergency diesel generators jacket cooling water
                      temperatures
           --
                      storage controls of portable equipment in safety-related
                      spaces
           --
                      makeup pump 1A inboard seal failure event that occurred on
                      December 29, 1985
           --
                      nitrogen blowdown of OTSG 1A level transmitter root valve
                      FW-V-1093 to free blocked line caused by Furmanite repair
      2.2 Assessments of Shift Inspectors
           2.2.1            General
                            The shift inspectors assured that any potentially adverse

i

                            safety concern or regulatory finding was identified prompt-
                            ly to both appropriate licensee supervisors and the NRC's
                            TMI-1 Restart Manager. Those items requiring additional
                            staff review or followup are described in paragraph 3 of
                            this report. Also, at the end of their assigned period of
                            shift inspection activities, the inspectors provided their
                            general assessment of facility operational readiness and
 ._ _
       ___      . . ,         . _ _ _
                                                           . . _ _       _ _ _ _ _-    _ _ .
                                                    12
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                           personnel performance. As noted below, these general find-
                           ings included, as applicable, the collective inspector
                           views related to operating staff performance, maintenance,
                           surveillance, radiological controls, training, emergency
                           planning, and physical security. The overall conclusions
                           of the TMI-1 Restart Staff are provided in the sections
                           that follow.
         2.2.2            Operator Performance
                           Licensed operators continued to demonstrate their detailed
                           knowledge of facility design and daily plant status.     This
                          was evident in their routine actions on shift and in re-
                           sponse to alarms and changing plant conditions. It was
  -
                           further evident in their overall good performance in re-
                           sponse to unexpected events such as the unusual event of
                          December 30, 1985, and for the unplanned reactor trip on
                          January 4, 1986. The shift organization in the control
                          room continued to demonstrate discipline and overall good
                          noise control in the control room. These same positive
                          attributes were evident during the off-normal situations
                          such as during the unplanned reactor trip.
                          Shift inspectors continued to note that, at the end of
                          shift, shif t foreman (SF) routinely cocied the control
                          room operators log entries for routine activities.     Although
                          the shift foremen were diligent in independently recording
                          entry in to technical specification action statements and
                          other off-normal events required by administrative procedures,
                          for routine entries the SF log lost its independence. This
                          could impact post-event reviews, since routine entries could
                          be used in reconstructing events. The Manager of Plant Opera-
                          tions acknowledged the inspector's observations and he
                          indicated that he would review the matter. This will be
                          routinely followed by the resident inspectors in future
                          inspections.
                          Of particular focus during this inspection period was li-
                          censed operator performance during the turbine trip test of

, January 2,1986. Overall, crew performance was very good.

                          All members were disciplined and attentive. They main-
                          tained their stations, observed appropriate instrumenta-
                          tion, reported important readings and alarms, and made
                          appropriate control manipulations. They were directed for-
                          mally by the Manager of Plant Operations, who kept them
                          apprised of overall plant status, concerns, and impending
                          actions. Despite the presence of many operators and ob-
                          servers in the control room, order was maintained and the
                          noise level was acceptable.
                                                                                                         .
    w w-    ---v es- --ec           -       = - - -    -,       ---                      --r----m-- +-y-

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                             13
,

!

       The test was conducted according to procedure.               Prior to
the test, a clear, concise briefing was conducted by the
       Manager of Plant Operations and a tast engineer. Prerequi-
!       sites, limits and precautious and procedural steps were
       read and discussed appropriately. Individual operator
       responsibilities were clearly assigned. It should be not-
       ed, however, that TP 800/9, STR-1 had been completely re-
       written during the week before the test.              STR-2 was not
       approved formally until December 31; and, three hours be-
       fore test time, the control room had not yet been provided
,
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       with a controlled copy.           Fifteen minutes before initiation
       of the test, operators reccmmended a change to an individual
       step, which was incorporated as a test exception by the
       engineer in charge of the test procedure.               During the test,
       the Quality Assurance (QA) observer independently cautioned
       operators to ensure that this change was not overlooked.
       Time pressures clearly affected this process but no adterse
       safety conditions resulted.
       The potential for operator error could have been reduced by
       more timely provision of the controlled copy of the proce-
I
       dure and by formal incorporation of changes identified
       prior to test initiation.
       Following the reactor trip, immediate actions of ATP 1210-1
       were clearly read by the shif t foreman. He waited for re-
       sponses to action or verification requirements before pro-
       ceeding to succeeding items.           Formal communications during
l      the rapidly evolving post-trip situation were good. Immedi-

j ate actions were promptly carried out as evidenced by

       starting of the second makeup pump four seconds after
       reactor trip.    The failure of MU-V3 to isolate letdown was
       promptly detected. Since the pressurizer outsurge due to
       post-trip cooling was stopped at an acceptable level, the
       decision not to marmally intervene immediately was demon-
strated to be acceptable.

i Annunciators were observed before they were silenced. Not

       all of them were formally announced, but there was no indi-
       cation that other than nuisance alarms were dismissed with-
       out announcements. Overriding of the nuisance alarm for
       reactor coolant system " Loop Flow High", which repeatedly

, entered, then clear,d, helped minimize noise levels and

       distractions.
       Data from the Bailey computer sequence monitor (acquired
       for post-trip review purposes) were lost. There was no

,

       indication of operator error in computer use during the
 '
       test.
   - _                     _
                               . _ _ . .    .   _        . _ _       -          - _ .
                                                                       1
                          14
      Following the reactor coolant pump trip, equipment problems
      prevented satisfactory demonstration of emergency feedwater
      system performance and resulted in EF-P1 being declared out
      of service. Operator actions, however, were appropriate
      during conduct of the test. The decision to terminate
      testing and restart the RC pumps to prevent further steam
      pressure decrease and to control cooldown was appropriate.
      Non-licensed personnel appropriately conducted themselves
      to support licensed operators during routine and special
     evolutions or testing. No adverse trends in performance
     were detected.
     Overall, personnel conducted themselves in a competent
     manner.

2.2.3 Training

     Shift inspectors made no specific observations on the
     licensee's training program. However, based on past TMI-1
     Restart Staff reviews into this area, previous conclusions
     on the training program remain unchanged. Operator perfor-
     mance continued to reflect a strong training program being
     in place for providing performance-oriented training. Spe-
     cifics on the non-licensed training program are in para-
     graph 8 based on Region I inspector review.

2.2.4 Maintenance

     For the maintenance activities selected for review, person-
     nel were knowledgeable in the technical aspects of the work.
     In general, their duties and responsibilities were understood.
     However, there continued to be evident less than full apprecia-
     tion of how poor work habits could challenge a safety system.
     Inspectors continued to note potentially adverse safety
     actions such as stepping on instrument air lines for climbing
     in the vicinity of MS-V13A/B, the initiation / isolation
     valves f,r steam admission to the turbine driven emergency
     feedwater pump. Further, the operator for MS-V10A, a bypass
     valve around MS-V13A, was stepped on for climbing. This
     occurred despite the fact that applicable job tickets were
     planned well in advance to provide temporary support or          ,
     ladders for these activities.     Licensee management recognized
     such poor practices as a problem for which they initiated
     corrective actions.     Apparently they were ineffective, to
     date, in reaching all personnel to explain the shortcomings
     of such poor work habits. This matter will continue to be
     routinely reviewed in future inspections by the resident
     inspectors.
                                                                                                                                       15
                                                                                                                   The troubleshooting for the abnormal performance of the
                                                                                                                   turbine driven emergency feedwater was conducted between
                                                                                                                  January 2 and 4, 1986. A job ticket and surveillance pro-
                                                                                                                  cedure was used to operate the pump on recirculation while
                                                                                                                   it was declared out of service. However, no formal data
                                                                                                                  were taken since the pump startups were termed by licensee
                                                                                                                   representatives as a part of the troubleshooting effort for
                                                                                                                  the pressure regulating valve. Subsequent to proper pres-
                                                                                                                   sure regulator adjustment, a satisfactory test was con-
                                                                                                                  ducted and recorded. However, the inspector noted to
                                                                                                                   licensee management that informal aspects of the trouble-
                                                                                                                  shooting efforts was a poor practice and could lead to a
                                                                                                                   lack of quality in the overall repair effort if errors were
                                                                                                                  made. No conditions adverse to regulatory requirements
                                                                                                                  were noted but the conduct of troubleshooting maintenance
                                                                                                                  will continue to be routinely reviewed by the resident
                                                                                                                  inspectors.
                                                                                                                  The Furmanite repair to a leak in a steam generator level
                                                                                                                  sensing line, to a certain extent, lacked good engineering
                                                                                                                  support of the reinjection process. Apparently during their
                                                                                                                  planning effort, licensee representatives did not consider
                                                                                                                  the potential for plugging the instrument line due to the
                                                                                                                  injection of too much Furmanite (a sealing compound). As a
                                                                                                                  result the line became plugged and the Furmanite plug had
                                                                                                                  to be blown into the steam generator. The licensee wanted
                                                                                                                  to restart the plant without a complete understanding of
                                                                                                                  the effects of the Furmanite material in the steam generator.
                                                                                                                  After probing by NRC staff and subsequent verbal discussions
                                                                                                                  among licensee engineers, licensee management concluded       l
                                                                                                                  that there were no unreviewed safety questions to plant
                                                                                                                  restart.    Subsequent to the startup, licensee personnel
                                                                                                                  documented their basis for no unreviewed safety question in
                                                                                                                  a 10 CFR 50.59 evaluation. This problem was indicative of
                                                                                                                  poor technical support for this work item. This item is
                                                                                                                  unresolved pending NRC staff review of the licensee's eval-
                                                                                                                  uation (289/85-30-01).
                                                                                                                  Although approximately 50 work items were completed by the
                                                                                                                  maintenance department between January 2 and 4, 1986, the
                                                                                                                  above examples were symptomatic of a sense of urgency that
                                                                                                                  could have the potential to result in error. Although no
                                                                                                                  adverse safety condition resulted, this is an area that
                                                                                                                  will be routinely reviewed by the resident inspectors.
                                                                                                            2.2.5 Surveillance
                                                                                                                  Surveillance activities were performed by both operations
                                                                                                                  and maintenance personnel. The activities observed were
                                                                                                                  handled in a professional manner.    All parties involved
                                                                                                                  were knowledgeable of the various systems.     Procedural ad-
                                                                                                                  herence was strictly observed.

h,me,. _ _ , __ _ _ _ _ _ , , _ _ . _ _ , . _ _ _ _ _ _ _ . _ _ _ _ _ ,, ___ , . _ _ _ _ _ _ _ _ _ _ _ _ _ _

                                       16
      2.2.6        Fire Protection
                  During inspection of the safety related areas, shif t in-
                   spectors continued to observe labeled fire doors " ajar"
                   (not fully closed, leaning on the latch mechanism). It
                  appeared that the doors had a problem with their closing
                  mechanisms and that personnel were not attentive enough to
                  assure proper closing of the doors. See paragraph 3.2.2 for
                  details on the TMI-1 Restart Staff followup review.
                  No adverse conditions to fire safety were noted.
     2.2.7        Radiological Controls
                  During this period the licensee culminated efforts to de-
                  contaminate the decay heat and building spray vaults to
                  permit access sufficient for observations without protec-
                  the clothing. This was conducive to    enhancing management
                  presence in all areas of the plant.
                  On December 22, 1935, a radiological controls area sign was
                  noted to be down and not observable. The group radiologi-
                  cal controls supervisor (GRCS) took corrective action but
                  this was a precursor of a more significant event. On Janu-
                  ary 9,1986, an individual walked into a high radiation
                  area without proper dose rate equipment.    See paragraph 6
                  for details.
                  Overall, proper radiological control practices were
                  implemented.
     2.2.8        Physical Security
                  No conditions adverse to plant physical security were
                  observed.

2.3 _Cqncl u si on

     Operators continued to conduct themselves in a competent manner and
     their actions reflected a strong performance-oriented training pro-
     gram.   Preparation for the turbine trip test was conducted at a fast
     pace but the pretest briefing had an organizing effect such that no
     adverse regulatory or s:fety conditions resulted.       In general, opera-
     tors were responsive to daily plant problems as they arose,
                                                                                i
     The maintenance department conducted an ambitious work list in a
     short period for the outage after the turbine trip test. That pace
     coupled with poor technical support on certain work items caused some

F

                                          17
           errors. Workers continue to exhibit poor practices in certain in-
           stances in which their actions could have an affect on the primary
           plant. Apparently licensee corrective actions to date where
           incomplete.
          Overall, procedures were properly implemented. Radiological control
          practices were good, however, there was a lapse in personnel atten-
          tiveness to reposting a high radiation area sign.
 3. Plant Operations
    3.1 Scope of Review
          TMI-1 Restart Staff inspectors periodically inspected the facility to
         determine the licensee's compliance with the general operating re-
          quirements of Section 6 of the Technical Specifications (TS) in the
          following areas:
          --
                review of selected plant parameters for abnormal trends
          --
                plant status from a maintenance / modification viewpoint in-
                ciuding plant housekeeping and fire protection measures
         --
                control of ongoing and special evolutions, including con-
                trol room personnel awareness of these evolutions
         --
                control of doc nents including logkeeping practices
         --
                implementation of radiological controls
         --
                implementation of the security plan including access con-
                trol, boundary integrity, and badging practices
         The inspectors also focused their attention on the areas listed
         below.
         --
                control room operations during regular and backshift hours,
                including frequent observation of activities in progfess,
                and periodic reviews of selected sections of the shift
                foreman's log and control room operator's log and other
                control room daily logs
         --
                followup items identified by shif t inspector activities
                (see paragraph 2)
         --
                areas outside the control r:en
         --
                selected licensee planning meetings
         As a result of this review, the inspectors reviewed specific events
         in more detail as described in the sections that follow.
                     - _ __.                     . _ _    _ _ . . - .      ._ .- .- __         .   _ _ _ _ _ . .--
i
                                                                      18
i
                             3.2 Findings

I 3.2.1 General

                                           Licensee management continued their presence and involve-

'

                                           ment in daily activities. The quality assurance department
                                           sustained their presence and detailed involvement in licensee
                                           activities. However, the pace of activities between Janu-
                                           ary 2 and 5 was hurried and it apparently caused a lapse in
                                           complete review of technical problems in preparation for
startup after the turbine trip. Specific problem areas
                                           were addressed in paragraph 2.2 for the short outage and
                                           performance problems noted below on a long term basis were

I

                                           indicative of this problem, that is, the thoroughness of
                                          management and technical support personnel review of plant
                                           problems.

"

                                 3.2.2     Fire Doors                                                              ,
                                                                                                                   ,
                                          The inspector reviewed the status of fire door maintenance
                                          and surveillance activities.           This review was conducted
                                          because of numerous shif t inspector observations of fire
                                          doors being not fully closed.
                                          As part of this review, the inspector toured Unit 1, held
                                          various discussions with licensee personnel, and reviewed

, the following documents.

                                          --
                                                 Preventive maintenance (PM) procedure U-27, "Func-
                                                 tional Testing of Fire Doors," Revision 0, dated June
                                                  19, 1985
                                          --
                                                 Surveillance procedure (SP) 1301-1, " Shift and Daily
                                                 Checks," Revision 58, dated September 5, 1985
                                          --
                                                 SP 1303-12.20, " Fire Door Inspection - Control Build-

, ing," Revisions 3 and 4, dated December 4, 1984 and

                                                 December 20, 1985, respectively

1

                                                                                                                   '
                                          --
                                                 SP 1303-12.21, " Fire Door Inspection - Primary Side,"
                                                 Revision 4, dated May 17, 1985
                                          --
                                                 SP 1303-12.22, " Fire Door Inspection - Screen House,"

1 Revision 4, dated December 11, 1985

                                          --
                                                 TMI-1 Fire Hazards Analysis, Fire Protection Program              a

i

                                                and associated documentation

. ! During a tour of the intermediate building on December 17,

                                          1985, at approximately 7:45 a.m. , the inspector observed
                                          fire door I-107 tied open with a piece of rope. No one was
  .- . - . _ , . - -           -       -                -                                  -.
            -.                   -      -      -                                .       . _ _ . -     -
                                                 19
                        observed in the immediate area. At approximately 11:30
                        a.m., the fire door was still open.                       The inspector brought
                        his concern to the attention of the shift supervisor; and,
                        shortly thereafter, the fire door was closed.
                        During discussions with cognizant licensee personnel, the
                        inspector was told that fire door I-107 does not separate
                        fire areas; it only separates fire zones. Also, it is not
                       part of a three hour rated fire wall and was not evaluated
                        in the licensee's Fire Hazard Analysis submitted to NRR as
                       part of their Fire Protection Program. After reviewing

! '

                       related documention, the inspector agreed with the licensee
                        representatives. The safety significance of leaving this
                        fire door tied open was minor and was not a violation of
                       technical specifications.
                       The inspector observed that most licensee personnel are not

l aware of which fire doors must be kept closed. Some fire

                       doors that do not have to be kept closed are labeled " Keep
                       Closed." Other fire doors that do not have to be kept closed
                       are not labeled at all (fire door I-107 was this type of
                       fire door). The inspector concluded that the labeling of
                       fire doors was confusing and brought this to the attention
                       of the licensee. Licensee management agreed that the
                       present labeling of fire doors was confusing and personnel
                       may not be sure which fire doors must be kept closed.
                       On January 6, 1986, the licensee removed " Keep Closed" signs
                       from all fire doors that do not have to be kept closed. Only

l '

                       those fire doors that are required by technical specification
                       to be kept closed are now labeled " Keep Closed." The licensee
                       stated that they would like to see the fire doors that are
                       not labeled remain closed as much as possible and will rely
                       on employee judgement to achieve this.                       The inspector found

l the licensee's action in this area to be satisfactory and

                       had no further questions.
                       The inspector also reviewed maintenance activities associ-
                       ated with these doors.          PM procedure U-27 provides an ac-

,

                       ceptance criterion that normally-closed fire doors will

'

                       close and latch when started from a 3/4 opened position and

l released. However, during discussions with licensee per- l sonnel, the inspector was told that PM procedure V-27 had

                       not yet been implemented. The licensee committed to place

'

                       this procedure into their preventive maintenance schedule
                       beginning in January 1986, and will initially perform it
                       twice per year. Based upon an evaluation of results from
                       this procedure, the licensee may reduce the frequency to
                       once per year.       The inspector found this action to be
                       satisfactory and had no further questions in this area.
 - - _ - . - - - _ - -    - - -     . . - -         - . - - - _ . - , _ _ - - -                         - - . - . .
                          20
      During the inspector's review of surveillance procedures
      associated with the fire doors, the inspector noted a
      discrepancy.    Fire door D-108, which is in a three hour
      fire rated wall, did not appear in any surveillance
      procedures.   This condition existed from December 16, 1985
      through December 19, 1985, when the fire door was not
      checked as part of SP 1301-1.
      Fire door D-108 was originally contained in SP 1303-12.22,
      Revision 3, along with screen house fire doors. The
      licensee decided that fire door D-108 would be more appro-
     priate in SP 1303-12.20, along with control building fire
     doors.    Procedure change requests were initiated to remove
      fire door D-108 from SP 1303-12.22, Revision 3, and to add
      it to SP 1303-12.20 as Revision 4. These procedures were
     attached and went into the change process as one package;
     both should have been issued together as new Revision 4
     procedures. However, SP 1303-12.22, Revision 4, was issued
     on December 11, 1985 and SP 1303-12.20, Revision 4, was not
     issued until December 20, 1985, when the inspector brought
     this issue to the licensee's attention.     Therefore, between
     December 16-19, 1985, the licensee did not survey fire door
     D-108. The inspector concluded that the above noted proce-
     dure change issuances were not properly coordinated and
     this resulted in an apparent violation of TS 4.18.7.2.c.
     (289/85-30-02)
     The licensee stated that security personnel routinely tour
     Unit 1 and shut any fire doors that may be open. The in-
     spector reviewed the security logs fcr the period of Decem-
     ber 16-19, 1985.     Security personnel did tour the diesel
     room area; however, they did not sign off on fire doors,
     only security doors. A senior licensee representative from
     security stated that checking closed fire doors was not
     part of the security guards' routine, but they would
     probably close a fire door if it was open.      The inspector
     had no further questions in this area.

3.2.3 PORV Exception and Deficiency J &D) Data Review

     The inspector reviewed data from surveillance procedure
     1303-11.45, "PORV Setpoint Check," Revision 5, dated Sep-
     tember 3, 1985, that was performed on December 20, 1985.
     This review was conducted because the PORV was declared
     inoperable due to three identified deficiencies.
                    21
The inspector found the surveillance package to be complete

with three deficiency sheets attached. The first deficien-

cy found the PORV high pressure reset to be out of toler-
ance high. The second deficiency founc the PORV
temperature interlock trip to be out c. tolerance high.

The third deficiency found the PORV low pressure reset to be out of tolerance low. The inspector questioned cognizant licensee personnel re- garding the cause of these three deficiencies. The inspec-

tor was told that instrument drift, dirty potentiometers,

or potentiometer adjustment relaxation were the most proba- ble causes. Corrective action for these three deficiencies consisted of recalibrating the bistables in accordance with procedures. A review of SP 1303-11.45 data from the past twelve months was conducted to determite if any obvious adverse trends existed. The inspector noted that the PORV temperature interlock trip was out of tolerance during the March and November 1985 surveillance tests. The inspector brought his concern to tha attention of the licensee. A representative stated that three recurrent de- ficiencies on the temperature interlock function would be picked up during trending reviews and action would probably be taken to correct the problem. In this case, the module would probably be replaced with a new module. As a result of the inspector's concern, the licensee initiated a cor- rective maintenance job ticket. The inspector concluded that corrective action taken by the licensee in response to the these deficiencies was appro- priate for the circumstances. The resident inspectors had no further questions in this area but will continue to rou- tinely follow deficiencies associated wfth the PORV. During the previously-mentioned review of past data from $P 1303-11.45, the inspector noted a confusing statement asso- ciated with the reset point for the PORV temperature inter- lock. The desired trip point is 275 F (-2.500 V) and the desired reset point is 278 F (-2.400 V). A footnote to the reset point states, " Required reset point is 0.100 1 0.050 y above trip point." However, the inspector noted several instances in which several I&C technicians used the wrong reset band. The reset band should be based upon the as-left trip point, not necessarily the desired trip point.

                           22
      The inspector brought this concern to the attention of cog-
      ni:ar.i licensee representatives.    They agreed with the in-
      spector that confusion exists among some I&C technicians as
      to what the resat band should be for the PORV temperature
      interlock. The licensee committed to revise SP 1303-11.45
      so that it is clearly understood that the reset point is
      based upon the as-left trip point.
      The inspector concluded that the probability of setting the
      reset point out of tolerance exists. Although the proce-
     dure was somewhat confusing, the inspector found it to be
      adequate.    Several instances were noted in which the wrong
      tolerance band was used; but, by chance, the as-left reset
      point was in tolerance to the proper acceptance criteria.

3.2.4 Makeup pump Lube Oil Pressure Switches

     On several occasions, the license has noted problems with a
     oil pressure switch associated with makeup pump 1A in that
     the switch was not stopping the motor driven lube oil pumps
     after proper oil pressure had been achieved using the at-
     tached lube oil pump. The motor driven oil pumps are used
     to supply lube oil when starting the makeup pump. Under
     normal running operations the motor driven oil pumps are
     secured and an attached lube oil pump supplies the neces-
     sary oil.     To secure to the motor driven oil pump, when
     proper oil pressure is generated by the attached oil pump,
     the pump has oil pressure switches installed as part of the
     control circuitry. The original lube oil pressure switches
     were not environmentally qualified.      The switches were re-
     placed with a qualified switches.     Evaluation by the
     licensee, determined that the pressure setting of switch
     was too high. The switch was eventually readjusted and is
     working correctly.
     The inspector reviewed and discussed the work that was per-
     formed on all three makeup pumps with plant engineering and
     maintenance personnel. Review of technical specifications
     indicated that the licensee remained in compliance of their
     technical specifications. Work performed was documented in
     accordance with applicable station procedures. The inspec-
     tor concluded that the inability of the lube oil switch to
     function as designed did not degrade the ability of the make-
     up pump to perform its safety-related function.

3.2.5 Diesel Generator Standby Coolant System

     As part of the routine plant tour, the inspector reviewed
     the auxiliary operators' logs. The Jacket coolant and lobe
     oil temperatures kept warm by the standby coolant system
     were consistently low out of specification. The normal
     values for jacket coolant temperature were expected to be
 _ __ -     _ _ _ - - - _ -            --     ._ -        . - -      _ _ _ = _ . - - _ - - _ _ - - .
                                                                                       _             --

l

                                                    23

l

                             120 F to 140 F.       The readings obtained by the auxiliary
                            operators on a shif t basis were between 112 F and 115 F.
                             The temperature of the lube oil is to remain above the
                            alarm setpoint of 90 F. The cause of the low temperatures
                            was attributed to check valve leakage in the standby coolant
                             system. (See NRC Inspection Report 50-289/85-26.)
                            The inspector queried the licensee whether the lower tem-
                            peratures had an adverse affect on the operability of the
                            diesel. From discussions with plant engineering and opera-                  *
                            tions personnel, the licensee demonstrated that the low
                            Jacket coolant temperature (temperature greater than 100 F)
                            would keep the lube oil temperature above 90 F. The actual
                             lobe oil temperature critical limit was approximately 65 F.
                            Review of diesel support systems indicated that lube oil
                            temperatures less than 65 F was the limiting condition as-
                            sociated with "keepwarm" systems. Review of licensee pro-
                            cedures demonstrated that sufficient operator action was
                            required to ensure that the lube oil temperature would not                  ;
                            drop below 90 F.
                            Further, licensee representatives indicated that the check                  -
                            valves in question would be repaired during the next outage
                            af ter the new internal components were received f rom the                  ;
                            manufacturer. The inspector questioned the licensee's phi-                  '
                            losophy of daily logs having out-of-specification readings
                            (see also paragraph 3.2.8). It appears that the licensee
                            was willing to accept out-of-specification readings until                   :
                            repair of the check valves could be accomplished. The                       !
                            licensee acknowledged this concern and they stated that                     '
                            they would review the applicability of the current speciff-                 ;
                            cation values.
        3.2.6               Letdown _. Cooler Isolation
                                                                                                        .
                            The inspector reviewed the sequence of events and the chem-
                            istry data associated with determining which letdown cooler
                            was leaking. The inspector initially reviewed the sequence                  j
                            of events during NRC Inspection 50-289/85-27. At the com-
                            pletion of that report the licensee was evaluating the cur-
                            rent information to determine which cooler was leaking.
                            From the chemistry plots, the licensee was able to deter-
                            mine that the 'B' letdown cooler had a leak rate of approxi-                :
                            mately 1 liter / day. The 'B' letdown cooler was isolated                   t
                            both on the primary and secondary side.                   The cooler has
                            been restricted to limited use under the direction of the                   ,
                            plant operation manager. Plant maintenance has started the                  '
                            necessary engineering and maintenance preparation to sup-
                            port replacement of the cooler during the next refueling
                            outage.
     . _ - _ - - _ - . - - - . . - - _ .                                      _  - _ .                . .         .
                                                                                                                             ---

l l

                                                                                                                                   1
                                                                                                                                   i
                                                                                                                                   ;
                                                                 24
                                                                                                                                   I
                                                                                                                                   !

'

                                                                                                                                   I
                                            The inspector reviewed the chemistry data and licensee rea-                            l
                                            soning for their conclusion of the "B" cooler leakage. The
                                            inspector discussed with plant maintenance and operational                             l
                                                                                                                                   ;
                                            personnel the limited use and the licensee's schedule for                              ;

l cooler replacement. It was concluded that limited use of the  !

cooler would not adversely affect plant safety. The un- t
                                            availability of a second cooler would only affect plant                                !
                                            operations during startups, and affect the length of time                              j
                                            to restart the plant from a cold shutdown condition.           The
                                                                                                                                   '
                                            inspector noted that because the leakage was small, the                                r
                                            licensee initially had difficulty in determining which                               . l
                                            cooler was leaking. After the 'B' cooler had been isolated                             i
                                            on both the primary and secondary side and the chemistry in                            !

l the intermediate close cooler was trended for a sufficient l period of time, the licensee was then able to determine I

                                           which cooler was leaking.                                                               !
                             3.2.7         Temporary Digital Readout for RM-A5
                                                                                                                                   I
                                            In order to easily read the indicated counts for the main                              '
                                           condenser offgas radiation monitor RM-AS, I&C technicians                               j
                                           connected a portable test equipment to the permanent read-                              l
                                           out in the control room. The portable test equipment was                                !
                                           placed (unsecured in any manner) on top of the cabinet con-
                                           taining RM-A5 readouts. The digital readout of the test
                                           equipment was thus used by the operators as an accurate
                                           method of quickly obtaining the count per minute reading
                                           for RM-A5.
                                                                                                                                   l
                                           The inspector questioned an I&C foreman on whether the test                             l
                                           equipment was considered permanent and should be considered                             I
                                           a missile hazard.                                                                       !
                                                                                                                                   !
                                                                                                                                   E

I The foreman stated that the equipment would remain until  ! l corporate engineering had designed a permanent resolution.  !

                                           The permanent resolution may be a new readout or just using                             i
                                                                                                                                   '
                                           existing arrangements. The foreman, however, acknowledged
                                           the inspector's concerns about the test equipment being a
                                          missile hazard. He immediately directed that securing                                    I
                                           straps be placed on the test equipment to ensure that it                                l
                                           could not become a missile hazard.                                                      :
                                                                                                                                   l
                                           The inspector reviewed the Interim solution and considered                              !
                                           it acceptable until the final engineering resolution was                                r
 ,
                                          developed.                                                                               !
                             3.2.8        Auxil_iary_ Operator Logs                                                                I
                                           The inspector reviewed selected primary system and secon-                               I
                                          dary system auxiliary operator (AO) logs completed during                                :
                                           the latter part of 1985.             The A0 logs are used by auxiliary                  l
                                                                                                                                   !
                                                                                                                                   !

!

   -                                     _ . , _ . .                _ - , _ _                   .----               - - . , . ~ -
       - -_       . - _ _                                                                                     _                                   . . _ . -                                                                      _ -    _ _ - . _ - - - .__ _ _ _ _                   _ _ - - - . . -

,

  ;
                                                                                                                                                                                                                                     25
  l
  i
 <
                                                                                                           operators to record numerous plant data and observations,
  j                                                                                                          If any data or observations are out of specification as
 i.
  '
                                                                                                             indicated by the reference values in the A0 logs, the aux-
            '
                                                                                                             iliary operator circles it to alert the reviewers (shif t
                                                                                                            foreman and operations engineers).                                                                                                                      Appropriate action, if
l                                                                                                          any, is then taken.
}                                                                                                         The inspector cbserved that there were frequent red-circled
                                                                                                            items throughout the A0 logs covering a period of several
 i                                                                                                       months. A licensee representative stated that the A0 logs
 ;                                                                                                        are used for trending purposes and that the reference values
 !                                                                                                       may not be accurate because the plant had not been operated
 !                                                                                                         for a long period of time.                                                                                                              The licensee representative
j                                                                                                        also stated that the vast majority of the red-circled items
 !                                                                                                       are not indicative of problems, and if they are, they are
 j                                                                                                       .rpropriately dispositioned.
 l
 l                                                                                                       The inspector concluded that the manner in which A0 log out                                                                                                                                  '
 }                                                                                                       of specification entries are being resolved was a poor
 )                                                                                                       operating practice. A red-circled item should alert opera-
                                                                                                         tions personnel that impending problems are evident. If
]                                                                                                        red-circled items are passed by week after week, the effec-
                                                                                                         tiveness of the A0 logs are greatly reduced. It could con-
                                                                                                        dition operators to treat " abnormal" readings as " normal"
                                                                                                         readings and corrective actions may not be taken. If the
4                                                                                                        reference values are not appropriate for the mode of opera-
 '
                                                                                                         tion, new reference values should be determined.                                                                                                                         The                 i

i resident inspectors will continue to routinely follow this ,

 ;                                                                                                     area.                                                                                                                                                                                          r
 i
 !
                 3.2.9                                                                                 Annunciator Black Goarcj                                                                                                                                                                       '

j On several occasions, the shift inspectors noted certain { annunciator alarms that remained lit for extended periods i 1 of time and other alarms that remain on permanently. For each j '

                                                                                                       alarm the inspector discussed the reason or cause for the
                                                                                                       alarm with plant operations personnel. In certain instanc-

] es the alarms were due to testing in the plant, however

j                                                                                                      some alarms were due to actual plant conditions and the way
                                                                                                       the circuitry was designed.

1 i

                                                                                                      Discussions with plant management indicated that the licensee                                                                                                                                   !
                                                                                                     was working toward having all annunciators out when the                                                                                                                                          ;
;                                                                                                     plant was operating at full power. The inspector discussed
j                                                                                                      the major annunciators that were continuously lit during                                                                                                                                       l
                                                                                                      plant operations. In each instance, the licensee satts-                                                                                                                                         '
i                                                                                                      factorily resolved the inspector's concerns about alarms
                                                                                                       that are continuously lit. However, the inspector questioned

1

{                                                                                                    why ground indications on both station batteries were period-                                                                                                                                    -

i ically received. Plant operations personnel stated that i l Job tickets were being written or have been written to ' 4

                                                                                                     correct the problem. The inspector verlffed that the                                                                                                                                             i

i

 a                                                                                                                                                                                                                                                                                                    v
                                                                                                                                                                                                                                                                                                      6
 ,
    ._        __     _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _
               . _ _ ...      __ _ _ _ _ _ .-_ _.-__.._ _ _                                               _ _ _ . _ _ _ - .                      _ - - . _ _ _ _ .        -
                                                                                                                                                                            l
                                                                                                                                                                            l
                                                                                                                                                                             '
                                                                                      26
                                                                                                                                                                            i
                                                             licensee was pursuing these problems; bat he also noted
                                                             that the battery ground problem was not being resolved ag-                                                     (
                                                             gressively by licensee management. The inspector had no                                                        (
                                                                                                                                                                            !
             ,
                                                             further questions in this area.
                                           3.2.10            Procedure Implementation
                                                                                                                                                                            l
                                                            As a result of a shift inspector concern identified during
                                                             the plant startup conducted on January 4, 1986, which re-
                                                             lated to the performance of a heat balance at approximately
                                                             30*4 power, the completed plant startup procedure 1102-2 was
                                                             reviewed and discussed with the licensee. The plant                                                            ;
                                                             startup procedure requires the performance of a heat bal-
                                                             ance at "approximately 30*4 power." This step in the com-
                                                             pleted procedure was initialled as having been performed.
                                                            A search of records showed a heat balance was performed at
                                                            41% power.                                                                                                      ;
                                                            Based on discussions with licensee personnel, the computer                                                      I

, used for performing the heat balance was unavailable at 30*4  !

                                                            power. Licensee management was present in the control room

l  ; i when 30*. power was achieved. Since the heat balance was  ! l

                                                            used to calibrate the power range instrumentation and the                                                       l
                                                            procedure calls for additional heat balances at progres-                                                        !
                                                            sively higher power levels prior to achieving 100*. power,                                                      i

l the decision was made to perform the heat balance specified , l l

                                                            at approximately 30*. power, later at 41*4 power when the                                                       l
                                                            computer was available. The actual power at which the heat                                                      !
                                                            balance is performed is immaterial for what it is intended                                                      ;
                                                            to accomplish, that is, for verifying the proper response

l of the power range instrumentation. Accordingly, licensee  !

                                                            management determined the performance of the heat balance                                                       ;
                                                            at 41% satisfied the approximate 30*4 specified in the
                                                            procedure. Based on this determination, the step requiring                                                      i
                                                            the heat balance at approximately 30*. power was signed of f.                                                   l
                                                            At the 41*4 indicated value, the power range instrumentation                                                    l
                                                            was recalibrated to 43*4 based on the heat balance calcula-                                                     L
                                                            tion. The inspector had no further questions relative to
                                                            this matter                                                                                                     .
                                                                                                                                                                            1
                                                            Procedure 1102-4, " Power Operation," in discussing the heat                                                    ;
                                                            balance requirements specifics heat balances at 15 and 30*4                                                     i
                                                            power.          This was identified as a typographical error and a                                              !
                                                            Procedure Change Request (PCR) has been prepared to have                                                        I

i

                                                            the procedure read 15 to 30*4 power to agree with the same

I requirement in Enclosure 5 of Procedure 1102-2. ,

                                                                                                                                                                            I
                                                                                                                                                                            i

l r -

                                                                                                                                                                            l
                                                                                                                                                                            i
 - , . - , .             -
                           -n                      -~,nn--         . . . - - .                  .-,--.,.,,,n                , , , , , , .- - _ -                  - - , .
                           27

3.2.11 Reactor Plant 0peration and _ Testing Activities Between

       January 5 and 10, 1986
                      _
       As previously noted in prior inspection reports, steam gen-
       erator water levels had been higher than expected due to
       apparent deposits on the secondary side of the steam gener-
       ator tubes. Following the most recent reactor startup on
       January 4,1986, the steam generator levels were at a lower
       level than had been expected. Due to the importance of
       steam generator levels to plant operations, a review was
       conducted to develop some assurance that the level readings
      were accurate. To accomplish this, five steam generator
       level instrument differential pressures on each steam
       generator were compared and found to agree with the
       instrument tolerances.
       The inspector verified that technical specification sur-
       veillance requirements for the instruments was verified to
      have been perforrned as required. The required weekly sur-
      veillance checks were verified to have been performed as
       required in accordance with Surveillance Procedure
       1301-4.1, Weekly Surveillance Checks, Revision 26, November
      24, 1983. Completed surveillance procedures for December
      28, 1985 December 20, 1985, December 13, 1985, and Decem-
      ber 7, 1985 were reviewed. Data showed all instruments to
      be accurate to within the specified acceptance criteria.
      The inspector had no further questions in this area.
                         .
      A sampling check of the licensee's control of locked valves
      was conducted.    Two valves BS-V-54A and BS-V-49A, normally
      locked-open valves, were noted as being unlocked and
      closed. A review of the control room locked valve log
      showed the valve positions were under the control of a sur-
      veillance test procedure and that their status was properly
      documented.
      The licensee's activities associated with a drop in instru-
      ment air pressure were observed.     Considerable personnel
      activity was noted in the intermediate building in the area
      of the instrument air compressors by individuals looking
      for possible instrument air system leaks. Also, announce-
      ments were made over the pubite address system for people
      using instrument air to discontinue doing so. A further
      evaluation by the licensee determined the loss of instru-
      ment air pressure resulted from the simultaneous venting of
      a number of air operated isolation valves.      The venting of
      the v41ves was in accordance with a surveillance procedure
      1303-5.1, Reactor Building and " Isolation System logic
      Channel and Component Test."      This procedure had not been
      perfortred previously with the plant at power and the loss
      of instrument air pressure was not considered. Further
 .. _. _ ._- _ _ . _ _ _                _ _            -_.. __ _ _ _ _ _ _ .- _ _               .     . _ _ . _ _ _ - . .
                                                                                                                            !
                                                                          28
                                                                                                                            ,

I I r '

                                             evaluation showed the use of instrument air was well within                    ;
                                             the capability of two air compressors and that following
                                                                                                                            ~
                                             this experience with the procedure, no problems should be                      -
                                            encountered during future perform 1nce of the surveillance.                    <
                                            Also, the licensee is evaluating a change to the procedure
                                            or the addition of a caution to help eliminate any future
                                            problems.
                                                                                                                           !
                                            During plant operation at 100% power on January 10, 1986,                      -
                                            some increase in the "B" main feedwater pump vibration was
                                            noted. Reactor power was reduced to approximately 78% and
                                            the feedwater pump was removed from service. The source of
                                            the vibration was traced to the pump coupling. The cou-                         ,
                                            pling was disassembled, cleaned, lubricated, new "0"
                                            rings installed, and reassembled. Portions of the pump                        i
                                            maintenance and subsequent pump restart were witnessed by
                                            the inspectors.           The pump maintenance and startup were ob-           l
                                            served to have been performed in accordance with appropri-                     '
                                            ate procedures and no deficiencies were noted. Quality
                                                                                                                           [
                                            control involvement in the maintenance activity and subse-                     t
                                            quent vibration data gathering wa> also noted.
                                            The repair of the control room position indication of the
                                            No. 4 main steam stop valve was observed.          This repair
                                            required the closing of the stop valve and the replacement
                                            of a broken rod associated with the position indication
                                            system by ISC personnel. The entire task was well planned
                                            between operations and I&C personnel, good communications                     I
                                            were established and maintained. The good planning and
                                            cooperation between operations and I&C personnel resulted
                                            in a swift and successful repair.
                         3.3 Conclusion
                              Licensee management and the quality assurance department continued
                              their presence and involvement in daily activities.              Problems were
                              noted in the thoroughness and completeness of management review of

, plant problems or at least in assurino thorough and complete techni- , L cal support personnel review of plant problems.  ! i

                                                                                                                          h
                              The poor operational practice of living with out-of-specification                           !
                              readings in daily logs was indirectly tolerated on a long term basis                        (
                              by intermediate managers, thereby conditioning operators to normal
                              " abnormal" readings. Individual procedure step inadequacies contin-
                              ued to be identified by inspectors indicating a problem with the at-
                              tentiveness of procedure reviewers and implementers to correct these                        :'
                              problems.       The labelling on fire doors was confusing and an improper-
                              ly coordinated procedure review resulted in a violation of a regulatory
                              requirement.                                                                                i
                                                                                                                          !
                                                                                                                          e
                                                                                                                          i
                                                                                                                          ;

r i

   _   _ _ - -       .   _ _ . _ _ _ _ _ _ - _ _ _ _ _ _ _ _.                          __   ._    _    _ . . . . _ .
                                                                                                                   .-
1
J
                                                                                                                       :
                                                              29                                                    -
                                                                                                                       ,

1

                Records of maintenance and surveillance activities were properly re-
tained. These records indicated that appropriate corrective action
i
               was issued for routine items needing repair along with proper post                                      !
               maintenance testing.                                                                                    !

i ] The startups after reactor trips were conducted in a deliberate and

conservative manner and operators continued to demonstrate their
highly developed skills in operating the integrated control system in

i manual. ) 4. Star _ tup Testing 1 4

     4.1 Test _ program Meeting Summary

i ! On December 17, 1985, a meeting was held at the TMI training center > in Middletown, Pernsylvania, to discuss the status of the power as- I cension program for TMI-1. Meeting attendees as well as the meeting j agenda and slides are identified in Attachment 1. The results of , l this meeting are summarized below.

               Because of apparent fouling problems on the secondary side of the                                       f

i

               steam generators, TMI-1 was not expected to achieve 100'e power. The                                    i
licensee plan of action was to proceed past 75*. power around December
i              27, 1985, and to reach whatever maximum power would be achievable                                       '

< with their present limitations. They would complete power ascension l test and around January 2, 1986, conduct the planned reactor trip l from maximum achievable power. Then if all prcceeded as scheduled, j the licensee would start up on January 3, 1986. The NRC staff agreed

l              that completing the power ascension program at the maximum achievable

! power vice 100*4 power would be acceptable. However, the licensee was ! requested to document its plan of action via formal letter. (This  : i was completed by letter, dated December 19,1985). 1 l The Itcensee also discussed in detail two situations which arose dur- 1 ing the startup. The first involved the EFW turbine-driven pump

               steam supply safety valves lifting wnen the pump actuates. The licensee                                 ,

,I

               has proposed an alternative interim solution which was acceptable                                       l
while further investigations were to be conducted. The staff empha- l

l sized that a final solution must be achieved by the completion of ' i cycle 6 refueling outage. The licensee was requested to document i l their plan of action via a letter. (This was completed by letter,  ;

               dated December 20,1985),                                                                                j
               The second situation involved main steam safety valves controlling

j steam generator secondary pressure upon a reactor trip instead of the i turbine bypass valves. Based upon investigative methods in process,

the staff concliund that the Ifeensee was appropriately addressing

i its concerns. (By letter dated December 20, 1985, the licensee con- s

               cluded no safety concern exists and they committed to notify the NRC
                                                                                                                       '

! ! staff of their review of test results by the restart after the eddy l current outage planned for March 1986.) i i r

                                                                                                                       I
                                                                                                                       l
i                                                                                                                     J
    . - .  -     _ - _ _     . .-.      -----._                  --       .-     -      _. - . . _ . -

1 i

                                                                                                       ,
i
'
*
                                                                                                       h
                                                  30
[

j 1 l l 4.2 PowerEscalationTestinL(MaximunAchievablePowerPlateauTesting} l i  !

i              4.2.1       Scope of Review                                                             l

}  !

j              4.2.1.1    Test Witnessing                                                              i

i At various times during the inspection period, the inspec- l 3 tors witnessed testing in progress on a sampling basis. ! However, test procedure (TP) 800/2, " Reactor Trip on Tur- j bine Trip," and TP 800/9, "EFW Pump Auto-Start Test," were

witnessed in their entirety by the TMI-1 Restart Staff.  !

l The tests were observed to verify that: s

                                                                                                       l
                                                                                                       i

1 --

                                   tests were conducted in accordance with appropriate                 i
                                                                                                       '
                                   test procedures;

) --

                                   prior to performing tests, an adequate briefing was

4

                                   conducted for operations personnel;                                 l

i  !

                          --

4 test trerequisites and initial conditions'ere

                                                                              w    met;                l
L

j --

                                   applicable tecnnical specifications were complied

4

                                                                                                       l
                                   with;                                                               -

f --

                                                                                                       f
;                                  operator actions were correct;                                      ,
                         --
                                   test engineers were knowledgeable in their duties;
                                   and,
i

! --

                                   test results were acceptable.                                       "
                                                                                                       ;
In addition to TP 800/2 and TP 800/9 witnessing, the fol- i

i Iowing tests were observed and/or their test results inde- i j pendently reviewed by the TM1-1 Restart Staff during this i l

                         inspection period.                                                            !
                                                                                                       !

,

                         --
                                   TP 800/5, " Unit Load and Steady-State Test"                        j

i ,

                         --
                                   TP 836/1, "Feedsater System Operation and Tuning"
                         --
                                   TP 849/1, "lCS Tuning at Power"

I i --

                                   TP 846/1, "Incore Thermocouple Operations Test"                     !

i --

                                   TP 8E5/2, " Turbine Bypass Valve Tes."

1

                                                                                                       t

l --

                                   TP 800/2, " Reactor Trip on Turbine Trip"

. l --

                                   TP 800/9 "EFW Pump Auto-$ tart Test"

i i '

!
:                                                                                                      ,
  _
                                      31
            --
                  CP 1105-14. " Loose Parts Monitoring System"
            --
                  RP 1550-08, " Core Power Distribution Verification"
            --
                  RP 1550-05, " Reactivity Coefficients at Power"
            --
                  SP 1301-9.5, " Reactivity Anomaly"
            --
                  SP 1303-1.2, "RCS Flow Surveillance"
           --
                  OP 1103-16, " Heat Balance"
   4.2.1.2 Test Results Review
           Test results from the testing program for the 83*. and 100*.
           power plateaus were reviewed by the inspector to verify
            that:
           --
                  test changes were approved and implemented in accor-
                  dance with acministrative procedures;
           --
                  changes did not impact the basic objectives of the
                  test;
           --
                  test deficiencies and exceptions were identified and
                  resolved and resolutions were acceptable;
           --
                  the cognizant engineering group has evaluated the test
                  results and signified that testing demonstrated that
                  design conditions were met; and,
           --
                  test results were within established acceptance crite-
                  ria or properly resolved.
   4.2.2   Licansea T e s t_J e s u_1_t s_a nd_]J RC F i n d i_n g .s
           Licensee performance of key tests is described in this sec-
           tion.     The discussion includes a summary of key test objet-
           tives and test results; test performance including
           operators, test engineers and equipment; and pertinent
           findings and outstanding problem areas identified and/or
           NRC findings as a result of testing. Cecause of the sig-
           nificanca of IP 800/2 and TP 800/9, the details on the per-
           formance of these tests and their results are discussed
           separately in paragraph 4.3.
           NOTE:     Paragraphs 4.2.2.1 through 4.2.2.6 discuss special
           tests performed at 88*. and 100*. Power levels except for IP

l '

           800/2 and 800/9 which are discussed in paragraph 4.3. All
           tests were completed by Janaary 10, 1986, prior to the end
           of this reporting period.               In somo instances, NRC review of
 i
 - - -   -     - -      - - _ - - - _ _ - -                          _ - _ - _ _    -
                                                                                       - -. --

l

                                                                                               '

l , ! * l 32 i l

                these data was conducted subsequent to January 10, 1986,
                however the results of this review are included in this
                inspection report for completeness.
       4.2.2.1  Unit Load Steady-State Test (TP 800/5]
                                                                                               ,
                The steady-state plant parameters were measured per TP
                800/5 at the SS*. and 100*. power levels. As noted in NRC

l Inspection Reports 50-289/85-27 and 85-28, the OTSG high l water level problem temporarily limited the achievable pow- l er to 88*i. Upon recovery from the TP 800/2 reactor trip l test, the steam generator water levels began to track with-

                in the original predicted range up to 100* power level and

I no longer impose operation limits on the reactor power.

               The rest of the steady-state plant parameters during                            I
               power escalation continuously showed good agreement with
               the predicted values.                                                            l
                                                                                                {
       4.2.2.2 Feedwater System _ Operation and Tuning _(TP 836/1)                             t

. The feedwater system operation was tested per procedure TP j l 836/1 at the 85*. and 100*. power levels. The measured l l feedwater flows and temperatures (af ter second stage high- '

               pressure heaters) agreed well with feedwater cycle perfor-
               mance predicted values. No unacceptable feedwater system                        t

l oscillations were observed during these tests. l l l l 4.2.2.3 ICS Tunino at Power (TP_849/1) (

               ICS tuning was completed satisfactorily at 88*. and 100*.                        l

l power. The significant portion of this test was a reactor

               runback on loss of main feedwater pump. On December 27,
               1985 at approximately 1:40 p.m., the licensee secured a
               main feed pump as per the test procedure. In a period of
               approximately five minutes the reactor rods inserted reduc-                      l
               ing reactor power f rom 88*. to 70*.. The transient was wit-
               nessed by the inspector. There were no plant equipment
               problems and the operators handled the transient properly.                       ,
               Test results were acceptable.                                                   l
       4.2.2.4 Incore Thermocouple _(T/C) Operations Test (TP 846/1)
               The incore I/Cs were checked at 88*. and 100*. power levels
               per procedure TP 646/1; four out of fifty-two T/Cs, identi-                     j
               fled as out of service during earlier testing, remained out                      l
               of service during these tests.                The remaining 48 operable          l
               T/Cs exceeded the minimum requirement of 16 operable T/Cs                        !
               located in a specified pattern.                                                  ,
                                                                                                !
                                                                                                l
                                                                                                I
                                                                                                l
                                                                                                t
                                               _ _ _ _ - _ .
                            33
        A problem identified during previous inspections at lower
         power plateaus was that the location of the five highest
         T/C readings as read from Mod Comp computer Area 3 groups
        8, 9, and 10 did not agree completely with the selection
        as determined by the computer program "TCDSPL." The data
        used for this comparison were taken at two different times.
        Due to the quasi-steady nature of the system response, and
        the small temperature difference among the higher T/C
        readings, this discrepancy was explainable. At the 88's
        power level test, as the temperature difference among T/Cs
        increased, the discrepancy only occurred at the fifth
        highest reading, whereas the first to the fourth highest
        T/C readings were correctly selected by the computer
        program "TCDSPL." At the 100*. power level test as
        temperature difference increased even higher, all five
        highest T/C readings were correctly selected by the comput-
        er program "TCDSPL."
       Other than as noted above, the functional check of all op-
        erable T/Cs and the associated computer system continuously
        showed acceptable results.

4.2.2.5 Core Power Distribution verification (RP 1,550-08)

       The detailed core power distribution at the 88*. power pla-
        teau was measured by the licensee per procedure RF 1550-08,
       " Core Power Distribution Verification," using the incore
       detector system. A procedure temporary change notice (TCN)
       No. 1-85-0206, dated December 26, 1985), was written to
       correct the predicted values for performing this procedure
       at a higher burnup and lower power level than originally
       planned. The inspector noted the following results:
       --
              The measured radial peaking factor for each assembly
              was consistent with the analytically predicted value.
              The comparison of the highest measured radial peaking
              factor (1.272) at core location K-11 agreed closely
              with the predicted value of 1.224.
       --
              The measured total peaking factor in each fuel assem-
              bly also agreed consistently with the predicted value.
              The highest measured total peaking factor of 1.463
              agreed well with the predicted value of 1.416.
       --
              The measured linear heat rates accounting for various
              uncertainty factors were within TS 3.5.2.7 limits, as
              indicated in the following table.
       - _ .  .
                                             _                                            . _ -               .-          - --                        ..           . _.
                                                                                                ..~
                                                                                                                 ,
 !                                                                                                                  v        34                                         l

J i

                                                                                                                                                                        '
                                                                                        -
                                                                                      h
;                                                                                                                                   Measured             Maximum

d

                                                                                                     Axial Location                Maximum *             Allowable
;                                                                                                    from Bottom                    Linear Heat          Linear Heat
!                                                                                       ,            of Ccfe                       Rate                  Rate
,                                                                                 s                  (ft)                          .(KW/ft)              [KW/ft)
                                                                                                                      * including:p wer spike factor
                                                                                                                                      ~
                                                                                                     11.14                           6.98                15.20
                                                                                                       9.43                       -11.82'                16.26
7.71 12.26- 17.10
                                                                                                       6.00                         11.88                17.50

I

                    ,
                                                                                                       4.29                         11;75                16.31
l
                                                 .
                                                                                                       2.57                         12.00                14.98

! , 0.86 9.20 13.50

I                                                                                                     ,

I

'
                                                                                                    The licensee also measured the core power distribution at
                    "
                      '
                                                                                                     100*. power on January 9, 1986. The inspector reviewed the
                '-
                                                                                                     test results and noted that the measured values were all
                                                                                                    within TS limits and consistent with the data obtained from
i
                                                                                                    88*. power results.

4

                                                                                                    All results were acceptable.
                                               4.2.2.6                                              Reactivity Coefficietts Measurement (RP 1550-05)

.

                               '
                                                                                                    The temperature and power coefficients of reactivity at

! the 88*e power level were measured per procedure RF 1550-05. l The measured temperature coefficient was -10.17 pcm/F.

                                      ~
                                                                                                    This value was in the test acceptance range of -14.0 pcm/F          1
                                                                                                    3 4 pcm/F. The temperature coefficient is the sum of the
             'i                                                                                     moderator temperature coefficient (MTC) and fuel doppler
coefficient. The corresponding MTC at 88*. power as
                                                                                                    derived from this measurement and the extrapolateJ value
                  -
                                                                                                    for 100?; power at an all rods out cendition are as follows:

1 Power Level MTC TS Limits

                                                                                                          (*41_ _ ,             IP.cm/F)        apcm/F)_
;                                                                                                          88
                                                                                                                   
                                                                                                                                   -8.7             <5
!
                                                                                                          100                      -8.2             <0

! . The measur.,[[ pone coef ficient (power doppler coef ficient, , I since RCS temperature was maintained constant during this

                                                                                                    test) was -8.59 pcm/*; power. This value satisfied the
                                                                                                    safety analysis requirement that the power doppler. coef f t-
                                                                                                    cient be more negative than -5.5 pcm/'. power. However, the
                                                                                                   measured value was slightly out of predicted range of
                                                                                                    -13.08 pcm/?; power + 4 pcm/?; power. The licensee nuclear
engineer performed an engineering evaluation and concluded

j that the measured power doppler coefficient has no impact

                                                                                                    on nuclear safety.

!

                                                                                                                                             '

!

                     %
            '

l , j

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

!

                                                                                                           .
                                                          35

i

              In addition, the licensee concluded that this value of the
             power doppler coefficient would not have special signifi-
             cance on operations.                                  This is due to the relatively small
             contribution of the power doppler coefficient on the overall
             reactivity calculation. The predicted doppler coefficient
              is used in two plant procedures: SP 1301-9.5, " Reactivity
             Anomaly," and SP 1303-15A, " Reactivity Balance." The in-
             spector reviewed the reactivity anomalies plot maintained
             by the nuclear engineering group since the beginning of
             this fuel cycle and noted that the measured values consis-
             tently agreed with the predicted values.
             Further, the inspector witnessed the plant startup on Janu-
             ary 4, 1986, and observed that the estimated critical post-
             tion (14% withdrawal on Group 7) was very close to the actual
             critical configuration (14.2*. withdrawal on Group 7). Based
             on these observations and independent verification of safety
             analysis assumed parameters, the inspector concurred with
             the licensee's engineering evaluation that there is no
             unreviewed safety question involved.
  4.2.2.7    Core Thermal Power (OP 1103-16, " Heat Balance
;
             Calculations")
             The core thermal power is usually determined by the plant
             computer (Group 55) which monitors the required input pa-
             rameters and performs a heat balance calculation. Hand
             calculation of heat balance is allowed as a backup when the
             plant computer is not operating. The inspector performed
             an independent calculation using the plant parameters taken
             at 10:38 a.m. on January 8,1986, for comparison.
                                                                        Plant             Inspector's
             Test Date                                            Group 55 Result         Calculation
                                                                 (MWt)   (% Power)      (MWt)    ($ Power)
             January 8, 1986                                     2532.91 99.92          2533.3     99.93
             (10:38 a.m.)
             This comparison indicated that the licensee's core thermal
             power calculation is adequate. Through control room obser-
             vation, the inspector noted that at about the same time,
             the power range indications NI-5 through NI-8 were consis-
             tent with the calculated core thermal power.
          __            - _ - _ _ _ - _ - _ _ .
                            _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _              __
                                                                                  .
                                                                                    .. . ..
                                                                  36
 4.3 Reactor Trip on Turbine Trip (TP 800/2) and Automatic Start of EFW
      Pumps on Loss of Reactor Coolant Pumps (TP 800/9)

1

      4.3.1      Reactor Trip on Turbine Trip (800/2)
      4.3.1.1    Test Performance
                 Restart condition 2.C.(1)(d) requires that prior to comple-
                 tion of the power escalation test program, the licensee
                demonstrate automatic reactor trip on turbine trip. This
                 test was performed on January 2,1986, in accordance with
                TP 800/2, Section 9.2, " Reactor Trip Due to Main Turbine
                Trip," during which the main turbine was manually tripped
                 from the control room console. Following the trip of the
                main turbine, the following events were expected to occur.
                --
                       reactor trip on the anticipatory turbine / reactor trip
                --
                       turbine bypass value setpoint transfers to 1010 psig
                --
                      containment isolation on reactor trip and reset features
                       function as designed
                                                                                            ,
                                                                                            I
                                                                                            i
                --
                      OTSG levels control at 30 inches by main feedsater
                The results of this test are discussed below.
      4.3.1.2   Test Results
                The test results indicated that the reactor had automati-
                cally tripped upon turbine trip. The maximum RCS pressure
                attained following the turbine trip was 2150 psig. The
                result was acceptable since it was below the reactor high
                pressure trip set point of 2300 psig.
                In addition to the automatic reactor trip on the anticipa-
                tory turbine / reactor trip; OTSG levels were controlled at
                approximately 30 inches using main feedwater; and partial
                containment isolation on reactor trip functioned vith one
                exception-letdown line isolation valve MU-V3 did not
                close. See paragraph 4.3.1.2.1 for further discussion.
                During the TP 800/2, reactor trip test, the inspector ob-
                served in the control room that the readings from source
                range instruments NI-1 and NI-2 indicated about 1 to 2
                decades difference. This subject was discussed with a
                cognizant licensee representative. Troubleshooting per-
                formed by I&C technicians immediately after the test
                indicated that NI-1 count rate amplification gain factor
               was out of tolerance. The gain factor was subsequently
                corrected per surveillance procedure 1303-7.2, " Source
                                                                   _ _ _ _ _ .
                                                       .   .                 .    __   .__ _ _
                                                                                                   l
1
                                                                                                   !
                                        37
                   Range Channel." The inspector witnessed the licensee I&C                        [
                   technicians perform a second confirmatory surveillance test                     .
                   on NI-1 and NI-2 on the following e y (January 3, 1986).                        '
                   Surveillance results indicated that both NI-1 and NI-2 had
                   been properly adjusted. (Both instruments properly responded
                   during the unplanned trip on January 4,1986.)
                   Another test objective, that turbine bypass valves control
                   turbine header pressure (1010 psig + 10 psi), was not satis-
                   fied due to lifting of the main steam safety valves. This
                   problem was first identified in the 40% power reactor trip

'

                   test (NRC Inspection Report 50-289/85-25, paragraph 4.2.3),
                   and a similar plant response was noted in the unplanned
                   reactor trip that occurred on December 1, 1985, at 75%
                   power. This problem is further detailed in paragraph
                   4.3.1.2.2 below.
                   There was also a concern as to the effect of the reacter trip

j on RCS and OTSG leak rates. This is discussed in paragraph i 4.4 where inspection efforts concerning RCS and 0TSG 1eak

                   rates are detailed.
,       4.3.1.2.1 Containment Isolation Valve MU-V3 Failure to Clost
                  As part of the turbine trip / reactor trip at 88% power per
                  TP 800/2, the licensee was to verify that containment isola-
                  tion valves shut on the reactor trip signal. During this
                  trip letdown isolation valve, MU-V3, failed to shut, al-
                  though it had previously shut during the trip at 40% power                       ,
                  per TP 800/2 during and a later inadvertent trip at 75%
                  power. The failure of MU-V3 to shut was identified as a
                  test deficiency.
                  Following the test, as part of troubleshooting mainte-
                  nance, the valve was successfully tested three times, in
                  that, it shut three consecutive times on a simulated reac-

-

                  tor trip signal. Further troubleshooting indicated that a
                  10 second time delay relay (62 X 1/MU-V3), which allows the
'
                  operator to open the valve after 10 seconds, was defective.
                  This relay was replaced. The retest on the job ticket
                  stated only that the valve was satisfactorily tested by the
reactor trip signal. TP 800/2, paragraph 2.1, stated, in
                  part, that one of the test objectives was to verify con-
                  tainment isolation on the reactor trip and that reset fea-
                  tures function as designed. The inspector noted that TP

'

                  800/2 failed to document the testing of the override / bypass
                  features for certain containment isolation valves.
                  A licensee representative stated that this was an over-
                  sight; however, the reset feature actually applied to
                  letdown isolation valve MU-V3, to allow restoration of

, letdown based on operator action. The licensee provided

                  documentation that the reset feature for MU-V3 was previously
                  tested August 10, 1981, per pre-operational test, TP 334/2.
  - - -        --   .                               -               - . - _ . . .    . - - _   __.
                                   38
               The inspector reviewed applicable portions of TP 334/2 and
               determined that reset function of MU-V3 had been adequately
               tested at that time. A complete NRC review of TP 334/2
               test data has been documented in an earlier NRC inspection.
               The inspector questioned whether the reset function for
              MU-V3 had been adequately t(sted during the power escalation
               test program.    The retest of job ticket CI 489, which
               replaced the time delay relay for the MU-V3 reset function,
              did not clearly document whether the timer and its reset
               function were fully tested. The inspector determined that
               there is no surveillance test procedure for the containment
               isolation function on reactor trip since this is not identified
               in the technical specification. The ability of MU-V3 to
              operate is tested quarterly per SP 1303-11.26, " Reactor
              Building Isolation Valve Cycle Test"; however, this procedure
              was not used as a retest for MU-V3 repair since it does
              test the automatic features of reactor building isolation
valves.
              On January 3, 1986, while the reactor was still shut down,
              the licensee performed a retest of MU-V3 by inserting a re-
              actor trip signal using the manual trip button.         Safety
              control rods, which had been withdrawn, were reinserted
              prior to inserting the reactor scram signal. MU-V3 shut
              after insertion of the scram signal and would not respond
              to an open signal until after 10 seconds.        The inspector
              witnessed the retest of MU-V3 and observed that the isola-
              tion and reset function did perform satisfactorily.         There
              were no further questions concerning the operation of
              MU-V3.
   4.3.1.2.2 Main Steam Safety Valve Actuation Fo11cwing Reactor Trips
              (Unresolved Item 289/85-25-05)
              During the reactor trip at 40% power performed on October 21,
              1985, the main steam safety valves and turbine bypass valves
              did not respond as expected. After the initial expected
              lift of the safety valves, some of the safety valves con-
              tinued to lift and reseat several times essentially providing
              pressure control in the steam header.        The turbine bypass
              valves failed to completely open and control pressure.
              This event was detailed in NRC Inspection Report 50-289/85-25.
             On November 21, 1985, during normal reactor power operation
              at 48% power, the licensee, tested and adjusted six select-
              ed safety valves in order to correct the above problem.
              The setpoints of five of the six valves tested were adjust-
              ed higher in order to preclude the potential relifts of the
              valves after a trip.     This was detailed in NRC Inspection
              Report 50-289/85-27.
 ,
                                    ~n                   -                      w - r
                                   39
               On December 1, 1935, the plant experienced an unplanned
                trip while at 75% power. During this transient, the main
                steam safety valves (safeties) on both steam generators
                initially lifted. The main steam safeties on the B steam
               generator appeared to reseat and the turbine bypass valves
               associated with B steam generator automatically took over
               and regulated the pressure in the generator. On the A
               steam generator the main steam safeties continued to lift
               and reseat several times thus controlling the pressure in
               the A steam generator. Approximately 12 minutes after the
               trip, the shift supervisor directed manual control of the A
               turbine bypass valves to lower steam pressure to below
               safety valve setpoints.
               Results from this trip, indicated the problem had not been
               resolved by the previous adjustment of safety valve setpoints.
              As a result, the licensee changed its procedures to have
               the operator take manual control of the turbine bypass
               system following a reactor trip. In addition, special
              monitoring equipment was installed on each valve and tele-
              vision cameras and thermographic instruments were set in
place to observe the main steam safeties lift during the
               scheduled trip at 88% power per TP 800/2.
              The trip from 88% power was performed on January 2,1986.
               It was agreed by plant personnel that the operators would      *
              wait until after the third lift of the safety valves before
              taking manual control of the turbine header pressure
              setpoint. On the first lift after the trip, the lifting of
              the valves were observed on three television monitors and
              recorded on video tape. On the second and third lifts,
              several plant personnel were sent on to the roof to person-
              ally observe and record which valves relifted.    It was ob-
              served on the trip that most, but not all, safety valves
              lifted. On the two subsequent relifts, only four to six
              valves relifted. As was observed during the earlier trip
              at 75% power, B steam generator pressure stabilized quicker
              than A steam generator pressure.
              The licensee is currently evaluating data and videotapes
              to determine the need for further corrective action.
              Licensee representatives stated that they will have a plan
              of action and schedule by the eddy current test outage
              scheduled for March 1986. This item remains unresolved
              pending further licensee action.
 __ _ _ _ . .        . _       _                                    _
                                                                            __
                               40
  4.3.2     EFW Pump Auto-Start Test (TP 800/9)
  4.3.2.1  Test Performance and Results
           Restart condition 2.C.(1)(f) requires that prior to comple-
           tion of the power escalation test program, the licensee
           demonstrate automatic EFW initiation on loss of all four
           reactor coolant pumps. This test was conducted following
           the reactor trip test per TP 800/2.
           Similar EFW pump auto-start tests have been performed twice
           during the power escalation test program; once during the
           40% power plateau transient test (TP 800/8, "RCS
           Overcooling Test") and once during the 3% power plateau
           natural circulation test (TP 700/2, " Low Power Natural Cir-
:          culation Test"). These two previous tests demonstrated
           that EFW pumps automatically started upon tripping both
          main feedwater pumps. Actuation times and pump discharge
           pressures were verified in these tests.    The objective of
           TP 800/9 test was to demonstrate that the EFW pumps automatical-
           ly start on loss of all reactor coolant pumps. Test re-
           suits indicated that the test objective was met. After
           verifying the test objective had been accomplished, steam
          driven pump EF-P1 and motor driven pump EF-P2B were secured
          and motor driven pump EF-P2A was kept running to support
          plant operations. Subsequently, all four reactor coolant
          pumps were restarted in sequence with no unusual plant re-
           sponse observed.
          Paragraph 4.3.2.2 below details further licensee action
          concerning the eperation of EF-P1 which were identified
          during performance of TP 800/9.
  4.3.2.2 EFW Steam Driven Pump Relief Valve Actuation (Unresolved
          Item 289/85-22-02
          During inspection 50-289/85-22 it was identified that both
          EF-P1 steam supply relief valves lifted. Although EF-P1
          operated properly, there was a concern that relief valves
          should not be challenged during routine operation and that
          a stuck-open relief valve could affect EF-P1 operability.
          This concern was identified as NRC unresolved item
          50-289/85-22-02. Licensee actions concerning this

, problem are detailed in inspection reports 50-289/85-24 and

          50-289/85-25, and paragraph 7 of this report.

j During previous troubleshooting it was noted that the re-

          lief valves did not lift when only one steam supply valve
          was opened. As an interim corrective action for the
          remainder of Cycle 5, the licensee replaced pressure con-
          troller PC-5 for steam pressure control valve MS-V6. MS-V6
                                                _      -_
 ,
                                        41

.

                   reduces steam pressure from a main steam header pressure of
                  greater than 900 psi to EFW steam supply pressure of less
                   than 200 psi.
                   In addition, EF-P1 steam supply valve MS-V13B was jumpered
                  out so that it would not open automatically with the open-
                   ing MS-V13A during an EFW actuation concurrently. If need-
                  ed, MS-V13B can be opened manually from the control room.
                  Keeping MS-V13B closed reduces the amount of steam to EF-P1
                  precluding the lifting of the relief valves.               The steam
                  supply to EF-P1 and the operability cf EF-P1 were satisfac-
                  torily tested several times during the startup test
                  prc ram.
                  During performance of TP 800/9 pumps EF-P1, 2A and 28 auto-
                 matically started as required when all four reactor coolant
                  pumps were secured. Although EF-P1 performed satisfactori-
                  ly in the recirculation mode, licensee personnel were con-
                  cerned that there may have been insufficient steam supplied
                  to reach sufficient flow and pressure for EF-P1 to supply
                  proper EFW flow to operating steam generators. Based on
                  this concern, EF-P1 was declared inoperable and a 72 hour
                  limiting condition for operation was declared.
                  Licensee calculations indicated that MS-V6 must open to at
                  least 45% open to rupply a sufficient volume of steam for
                 EF-P1 to properly supply operating steam generators. The
                 MS-V6 controller was re-adjusted and the pump tested sever-
                 al times until an opening of 45% and steam supply pressure
                 of greater than 180 psig (but less than 200 psig) was
                 achieved.      EF-P1 was satisfactorily tested and declared
                 operable prior to restart af ter the 88% power trip.
                 Item 50-289/85-22-02 remains unresolved until the licensee
                 establishes permanent corrective action concerning the op-
                 eration of MS-V13A and MS-V13B.          The licensee has committed
                 to a permanent resolution prior to the startup after the
                 next refueling outage (Cycle 6).
   4.4 RCS and OTSG Leak Rate
        4.4.1    Effect of Reactor Trips from 88% and 22% Power on RCS and
                 OTSG Leak Rates
                 The effect of reactor trips from 88% and 22% power on RCS
                 and 0TSG 1eak rates was followed up by the TMI-l Restart
                 Staff. Based on data review of surveillance procedure (SP)
                 1301-1, " Shift and Daily Checks," aod SP 1303-1.1, " Reactor
                 Coolant System Leak Rate," the inspector noted that both
                 RCS and OTSG 1eak rates on the days following these trips
                                                                                       ;
                                                                                       ,
                                                                                       !
                                          _--     -- -     - - _ _   - . - -

.

                            42
        (January 3-5, 1936) remained well within the the technical
        specification's limits and were consistent with the previ-
        ous results. No abnormal conditions wer observed.
 4.4.2  RCS Leak Rate Change Evaluation
        During a routine NRC shift inspector review of plant opera-
        tion data, the inspector noted that the caiculated uniden-
        tified leak rate varied from -0.12 gpm (2 a.m.) to -0.26
        gpm (10 a.m.) on December 22, 1985.    The shift inspector
        noted that while the plant was operating at steady-state *
        75% power level, the only plant condition that could affect
        the leak rate result appeared to be a change in reactor
       coolant drain tank (RCDT) pressure.
       To resolve the abeve discrepancy, this matter was further
        reviewed by the TMI-1 Restart Staff. The RCP No. 3 seal
       purge flow is directed to the RCDT. Since this flow is
        supplied from the reclaimed water system and is not classi-
        fied as RCS leakage, its contribution to the RCDT mass in-
       vec. tory change has been properly factored into the RCS leak
       rate calculation. The seal purge ficw is assumed to be 100
       cc/ min per pump or approximately 0.10 gpm for four RCPs.
       This assumption is consistent with the actual seal purge
       flow guidance provided in the RCP operation procedure
       (CP) 1103-6. The seal purge flow local instrument is lo-
       cated inside the reactor building. Due to difficulty in
       determining the actual flow rate on a routine basis, and
       because this term is small in nature, the value of 0.10 gpm
       is therefore taken as a constant in the calculation. Since
       the RCDT pressure affects the seal purge flow, increasing
       the RCDT pressure may cause the actual flow rate to deviate
       from the assumed value of 0.1 gpm which in turn may have
       a small impact on the leak rate calculation.
       The current RCS leak rate calculation used by the licensee
       was actually field tested during hot functional testing
       conducted in 1984.    Under controlled environmental condi-
       tions, the current method was proven to be able to detect
       RCS leakage in the order of about 1 gpm with a 0.1 gpm
       variation. The relatively large variation, as observed by
       the shift inspector on December 22, 1985, was regarded as
       due to the increase in RCDT pressure and the inherent
       calcciation allowances associated with the current surveil-
       lance technique, and therefore was determined to be a
       normal plant response.
 4.4.3 RCS Leak Rate Eva  c orative Loss Term
       Through various inspections conducted since the TMI-1 hot
       functional test, the evaporative loss term was identified
       as having contributed to the negative unidentified leak
                                       43
                  rate result.    In the routine tracking of RCS leakage during
                  the extended period of startup testing program further
                  confirmed this finding; that the correct evaporative loss
                  term for the current plant condition is essentially zero.
                  In the meeting between TMI-1 Restart Staff and the licensee
                  management held on January 2,1986, the licensee agreed
                  that this evaporative loss term will be set to zero in the
                  RCS leak rate calculation and will be implemented before
                 January 31, 1986, pending the completion of computer soft-
                  ware changes.
 4.5 Verification of Licensee / Restart Conditions
      4.5.1       Verification of License Conditions

'

                  Licensee condition 2.C.(8)3 states that "GPU Nuclear Corpo-
                  ration shall complete its post-critical test program at
                 each power range (0-5%, 5%-50%, 50%-100%) in conformance
                 with the program described in Topical Report 008, Revision
                 3, and shall have available the results of that test pro-
                 gram and a summ y of its management review, prior to as-
                 cension from each power range and prior to normal power
                 operation."
                 Management reviews for the power ascension test program
                 were documented in three reviews called flag reviews. The
                 first flag review (Flag 28) was conducted on May 9,1985,
                 and authorized TMI-1 to proceed with hot functional testing
                 through 48% power. Flag 2B verified plant readiness for
                 testing and was based on an anticipated restart during June
                 1985. Because of court decisions, restart of TMI-1 was
                 delayed twice. Based on these delays, the licensee updated
                 its Flag 28 approval on August 27, 1985, and on October 2,
                 1985.
                 The Flag 3 review was conducted on November 15, 1985 and
                 authorized the plant to proceed from 48% to 100% power.
                 Because of high steam generator levels the plant was only
                 able to achieve 88% power per TP 800/2 on January 2, 1986,
                 the licensee considered the power escalation test program
                 complete. Flag 4 was conducted on January 3,1986, and the
                 plant was authorized to restart and achieve the maximum
                 power for commercial operation.
                 On January 6, 1986, the plant achieved 100% power. Further
                 test data were taken after reaching 100% power; however no
                 further flag meetings were required.
                 The inspector reviewed the summaries of flag meetings and
                 noted that there was a high level of management attention
                 given to these meetings. Each flag review was signed by
                      _.
                                                                        I
                             44
         the President of GPU Nuclear, five vice presidents, and the
         chairman of the General Office Review Board. All test data
         results, including test exceptions and deficien ies, were
        made available to the NRC Restart Staff shortly after data'
         reduction and review had been completed. All test data
        were subsequently reviewed by the Test Approval Group (TAG)
        at formal meetings. The T/G consisted of representatives
         from Startup and Test, Plant Staff, Nuclear Steam Supply
        Systems, Technical Functions and Quality Assurance. In
        addition, most TAG members were supervisory or managerial
        personnel.
        Although a flag meeting was not conducted at 5*; power be-
        fore proceeding to 48*;, the staff concludes that the Flag
        2B meeting prior to restart and the TAG review of test
        results at 5*4,15'J, 25*; and 40*; test plateaus meet the
        license condition. Based on the above review, the inspector
        determined the licensee review of restart test programs was
        in conformance with license condition 2.C.(8)3.

4.5.2 Veri'ication of Restart Conditions 4.5.2.1 Res: art Condition (2) (d)

       Restart condition (2) (d) states that " Prior to completion
       of the Power Escalation Test program, GPU Nuclear Corpora-
       tion shall demonstrate safety grade automatic anticipatory
       reactor trip on loss of feedwater and upon turbine trip."
       The reactor trip on loss of feedsater was demonstrated dur-
        ing the trip test per TP 800/2 at 40*. power.    Thi s was ver-
       ified by the NRC and documented in NRC Inspection Report
       50-289/85-25.
       Performance of the reactor trip at 88*; power per TP 800/2
       on January 2,1986, demonstrated reactor trip upon turbine
       trip.    Based on the above, the licensee has met the re-
       quirements of restart andition (2) (d).

4.5.2.2 Restart Condition (2) (e)

       Restart condition (2) (e) states that " prior to completion
       of the Power Escalation Test program, GPU Nuclear Corpora-
       tion shall demonstrate performance of the saturation meter,
       the incore thermocouples, and the wide range hot leg tem-
       perature instrumentation systems installed to recognize
       inadequate core cooling."
       The saturation meter was tested initially in 1981 per TP
       645-1, " Test Functional Test," and then retested in 1984
       following modification to Class 1E qualified temperature
       inputs, per TP 700/1, " Controlling Procedure for Low Power
                                      45
                  Physics Testing," enclosure 16, "Tsat Margin Comparison."
                  Wide range hot leg temperatures were tested initially
                  in 1981 per TP 657/1, "Non-Nuclear Instrumentation
                  Hot Operation and Calibration," and were retested in 1983
                  following installation of Class 1E RTDs, per TP 700/1, en-
                  closure 12, " Data Collection Sheets for Modifications
                    1-38, LM-43C and RM-13J."     Verification of satisfactory
                   erformance and data review for the above tests were accom-
                  plished during several previous NRC in:cections.
                 The incore thermocouples were tested during the power esca-

"

                  lation test program per TP 846/1, "Incore Thermocouple
                  Functional Test." Verification of final satisfactory per-
                  formance of this test is detailed in paragraph 4.2.2.4 of
                 this report.
                 Based on the above, the licensee has met the requirements
                 of restart condition (2) (e).
      4.5.2.3    Restart Condition (2)(f)
                 Restart condition (2)(f) states that " Prior to completion
                 of the Power Escalation Test program, GPU Nuclear Corpora-

,

                 tion shall demonstrate EP4 initiation on loss of all four
                 reactor coolant pumps."      Performance of TP 800/9 on January
                 2,1986, verified the automatic start of all three EFW
                 pumps upon the loss of all four reactor coolant pumps.
                 This test is discussed in paragraph 4.3.2. Based on this,
                 the licensee has met the requirements of restart condition
                 (2)(f).
 4.6 Startup Testing Program Completion
      4.6.1     Test Program Summary
                The licensee's startup testing program from zero power
       .        physics testing to the low power natural circulation test
                at 3?e power was controlled by the test sequence procedure
                TP 700/1, and power escalation testing was controlled by TP
                800/1. The testing program included performance of various
                tests and was, on a sampling basis, found to be consistent
                with the FSAR, technical specifications and specific licensee
                restart condition requirements. The startup testing program
                was successfully completed on January 2, 1986, following
                the completion of the 88*4 power reactor trip test, and with
                the licensee's subsequent management review.
                As described in previous inspection reports (50-289/85-27
                and 85-28), the steam generator level versus reactor power
                tracked higher than expected during the power escalation
                program, in that it limited the maximum achievable power
                to about 88*. Unexpectedly, as TMI-1 returned to power
                          -.- - - ..     -
                                             - -.
                                 46
             on January 4,1986, the steam generator water levels no
              longer imposed an operational limit on the reactor power
              level. The reactor trip test and the subsequent unplanned
             trip at 22% power, which occurred during the plant restart
             on January 4,1986, apparently resulted in redistribution
             of deposits in the steam generators. This apparent redis-
             tribution allowed the plant to achieve a higher power level.
             The plant achieved full power operation on January 6,1986.
             The licensee conducted additional full power tests that
            were deferred because only 88% power could be achieved prior
             to the reactor trip test. Subsequent to this inspection
             period, the TMI-1 Restart Staff independently reviewed the
             additional test data and found the test results acceptable.
    4.6.2   Overall Test Exceptions and Deficiency (E&D) Review
             The licensee startup test and reactor engineering groups
             have successfully completed the startup testing program.
            Test results were properly reviewed by the cognizant engi-
             neers and/or testing personnel. Final test results were
             reviewed and approved by Test Approval Group (TAG). All
            test exceptions and deficiencies have been identified and
             resolved, and resolutions were acceptable.

. 4.6.3 Restart Test Program Evaluation

            On April 5, 1933, the licensee, by letter, submitted to the
            NRC a description of its test program following NRC author-
             ization to restart the TMI Unit I reactor.    The test plan-
            ning specification (SP-1101-06-008) was attached to this
            letter and identified the items to be tested; the plant
            status for testing; the formal commitment for the test; the
            test scope and acceptance criteria; and the test procedure
            which would perform the test.
            During this inspection, the inspector reviewed the
            licensee's test planning specification to determine if all
            commitments identified for the power escalation test (PET)
            program had been met.
            In general, the licensee had met its commitments as defined
            in the planning specification.    However, some discrepancies
            were noted and are identified below.
    4.6.3.1 The test for modification RM-5C, " Containment Isolation on
            Reactor Trip," requires the verification of proper contain-
            ment isolation following the 40% and 100% reactor trips and
            that the override and bypass switches allow valves to re-
            open. The inspector noted that TP 800/2 failed to document
            the reset feature of containment isolation valves. The
            reset feature currently caly applies to one valve, MU-V3,
 .-   ._.            . _-             .                  _    _
                                   47
              " Letdown Isolation Valve." Resolution of this issue is
              discussed in paragraph 4.3.1.2.1 of this report.
   4.6.3.2    The licensee stated that turbine generator (TG) operation
             would be tested per TP 8S5-1.       TP 885-1 was to verify ac-
             ceptability of various TG acceleration, speed and loading
              parameters and characteristics and to verify proper
             performance of the TG versus load at (15, 40, 76 and 100%
             power). A review of TP 885-1 indicates that only steady-
              state parameters such as temperature, thermocouple perfor-
             mance, and vibration measurements were performed at various
             power levels.
             A licensee representative stated that turbine load testing
             parameters were tested per a special GE load test performed
             by GE during hot functional testing. The licensee provided
             to the inspector documentation of turbine generator load
             testing, " Control Systems Checkout Prior to Restart," which
             was performed during the period of October 27, 1981, through
             December 18, 1981. This testing performed a comprehensive
             checkout of turbine controls under load conditions.
             Based on the above documentation, the inspector considers
             this test commitment to have been satisfied.
   4.6.3.3   Turbine bypass valve testing acceptance criteria in the
             test specification state that turbine bypass valves shall
             open in < 3 seconds at < 1100 psia peak pressure.              The pro-
             cedure allows a peak pressure of < 1155 psig. A licensee
             representative states that pressures were based on startup
             test, TP 800/6 performed in 1974.       TP 800/6 acceptance cri-
             teria stated peak OTSG pressure should be < 1100 psia (1085
             psig) and shall be < 1180 (1155 psig).       These acceptance
             criteria were not clearly translated into the planning
             specification.
             For the test (TP 885/2) the actual peak pressure recorded
             by the transient monitor during the 40% and 88% trips did
             not exceed 1060 psig. Because the main steam safety valves

'

             controlled pressure (see paragraph 4.3.1.2.2), the opening
             times of the turbine bypass valves could not be measured.
             This is a test deficiency which, when closed, will be
             resolved by the licensee. Based on the above, the inspector
             considers that the intent of this test commitment has been
             met.
     6.1 4   The licensee stated that they would perform a natural
             circulation level control test to determine the lowest lev-
             el in the OTSG that sustains natural circulation flow while
             on main feedwater.      This was to be performed by TP 800/9
             following the reactor trip from (an anticipated) trip at
                                                                                     ..
                 -           . _ .         __ -   _.              _ - _ _ .
 -        ..
                      -
                                                                 .  .           .-
                                                                                            . _ _ .-
                                                      48
                                   100% power. This test was to be performed at the request of
                                  the licensee's engineering organization.
                                  During the startup test program several weeks prior to the
                                  performance of the final trip test per TP 800/2, the
                                   licensee notified the NRC Restart Staff verbally that the
                                  natural recirculation level control portions of TP 800/9
                                  would be deleted. This was acceptable to the restart staff
                                  since this test was to be performed at the licensee's dis-
                                  cretion and was not based on any formal regulatory commit-
                                  ment or requirement.
                                 A natural circulation level control test was performed
                                  during the natural circulation test at 3% power during
                                  performance of TP 700/2.    During this test OTSG level was
                                  controlled by emergency feedwater and natural circulation
                                 was lost at approximately 35% OTSG 1evel on the A steam
                                  generator.
                                  Licensee representatives stated that sufficient data were
                                 obtained during TP 700/2 because further natural circula-
                                 tion level control testing was unnecessary. Based on the
                                 above, the inspector considers that the licensee has met
                                  the intent of this commitment.
                      4.6.3.5    As part of its restart commitment, the licensee stated
                                 that after performance of TP 800/8, "RCS Overcooling Con-
                                 trol Test," operating procedure (0P) 1102-16, "RCS Natural
                                 Circulation Cooling," would be reviewed to ensure that it
                                 provides adequate guidance to prevent overcooling during
.
!
                                 any natural circulation cooling. The inspector questioned
                                 whether or not this had been done as this commitment was

,

                                 not part of the test program itself.
                                 Discussions with licensee representatives indicated that

i the Technical Functions Division located at the corporate

;
                                 office had the lead responsibility for changing this proce-
                                 dure.    The inspector reviewed several memoranda by Tech-
                                 nical Functions indicating that extensive reviews were being
                                 done as result of data obtained from the test. Simulator
                                 programs and operator training will be upgraded as a result
of data obtained from tests TP 700/2 and TP 800/8. Howev-
                                 er, these memoranda do not address plant procedures.
                                 The cognizant engineer stated that he was aware of the com-
                                 mitment and was planning to revise OP 1102-16 in the near
                                 future. To ensure that this commitment would be tracked,

'

                                 the Manager of TMI-1 Startup and Test, Technical Functions,
                                 submitted a technical functions work / task request (TR No.
                                 BT 4410), which requests that the results of TP 700/2 and
                                                                         .
  - - . . - . , - . ,   - ,. -
                               ,       ,   -,-
                                                                                                                         - _ -
                                                            49
                                   TP 800/8 be reviewed and that procedural recommendations be
                                    incorporated into OP 1102-16. The inspector had no further
                                   questions concerning this item.
       4.7 Ouality Assurance / Quality control (0A/0C) Interface With the Startup
            Test Program
            Throughout the startup test program, the inspectors observed QA per-
            sonnel witnessing test performance and reviewing test procedures
            while in progress. The inspector discussed the test inspection pro-
            gram with QA management, interviewed QA inspectors on shift and re-
            viewed documentation of completed shift monitoring. QA overview of
            test programs was under the cognizance of the operations QA manager
            and performed by shif t monitoring engineers (SMEs).
            SMEs monitor selected activities in the plant and there was at least
l           one SME on shif t at all times. During testing, when needed, two SMEs
           would be assigned to a shift. SMEs are engineering graduates who
            have qualified for the position. During th test program several QC

i inspectors were qualified as SMEs in order to augment test program

            coverage.                  There was at least one SME assigned exclusively to cover

1

i
            the test program. Rather than oerform audits or per' arm specific
            inspection points, SMEs performed a monitoring overview. SMEs on a
            sampling basis reviewed data, verified test procedure compliance,

'

           assured that the latest revision of procedures were in use and veri-
            fied test equipment calibration.
           Prior to the start of the test program, the operations QA section
           developed a detailed monitoring plan. This plan detailed areas to                                                                 be
           monitored in each phase of testing, assigned responsibilities, and
           documented subsequent monitoring by recording QA monitoring report
           (QAMR) numbers. The inspector noted by documentation of QAMRs that
           extensive monitoring was done in each area. In addition, the inspec-
           tor reviewed seven randomly selected QAMRs which were accomplished
           during different phases of the test program. The QAMRs were compre-
           hensive, in-depth, and indicative of detailed QA inspection coverage.
           In addition to tests in progress, QA reviewed all completed test data
           and exceptions and deficiencies.                      The operations QA manager is a mem-
           ber of the test acceptance group (TAG). QA has an input to the
           fi        acceptability of test results. As a result of QA participating
           in IAG, 100% of all completed data is reviewed.                                      In addition to test
           procedures, QA provided documentation that license conditions, startup
           conditions, and other regulatory commitments made by GPU Nuclear were
           being met. Periodic memoranda are forwarded to the Vice President /
           Director of TMI-1 concerning the status of GPUN's ef forts to satisfy
           licensing commitments to the NRC.
           Based on inspector observations of QA monitoring and extensive docu-
           mentation of QA monitoring, the inspector considered the monitoring
           program to be thorough and extensive.

,

  7---         - - ,   - , _ , - - - - . , ,,   - _ _ - - -    -             , - _ - - . , - - - - . - - - - - - - - - -       - , , - , , ,    - - - -
                                          50
    4.8 Conclusions
          The nuclear engineering group consistently performed well throughout
          the entire startup testing period.      The physics testing program was
          well prepared and executed. The test data were properly evaluated
          and information was disseminated to the appropriate groups. The
          startup testing group also performed well in coordinating and identify-
          ing plant equipment problems.      Equipment or procedural problems
          identified in the early stages of testing were quickly corrected and
          implemented during the remaining testing period.
          Overall, the testing program was effective and provided an adequate
          test of overall plant equipment performance, plant operator perfor-
         mance, and the ability of safety systems to perform adequately.

5. Event Review

    5.1 Reactor Trip / post-Trip Review
         The resident and region-based inspectors attended the licensee's post-
  ,       trip review of the trips on January 2 and January 4,1986.        This re-
         view was required by administrative procedure 1063, " Reactor Trip
         Review Process." The January 2, 1986, reactor trip review identified
         several problems that were corrected or appropriate corrective action
         was initiated by the licensee. Additionally, the review noted that
         portions of the computer program (transient monitor) used to compute
         sequence of events did not function.      The sequence of events computer
         program was subsequently retested successfully and the licensee was
         unable to reproduce the problem. The sequence of events monitor
         functioned properly during the January 4,1986, trip, but the licensee
         decided to closely monitor its function on a daily basis;
         The cause of the trip on January 2, 1986, was a manual turbine
         trip / reactor trip as part of the power escalation test sequence which
         was described in paragraph 4. The trip on January 4,1986, was due
         to failure of the level controller associated with a feedwater heater
         drain tank which resulted in high level in a moisture separator tank.
         The moisture separator 1-of-1 instrument logic provided a turbine
         trip which caused the reactor trip.
         For both trips, the inspector independently reviewed the completed
         enclosure 1, " Post Trip Review of AP 1063," and the recorder strip
         charts and verified that the data required by enclosure 1 were re-
         trieved with no significant deficiencies noted. The inspector con-
         cluded that the procedure adequately evaluated plant performance to
         the extent necessary to reach a decision related to startup. In ad-
         dition, the inspector confirmed the l'censee's conclusion,
                                                                                    i
                                   51

5.2 Radioactive Gas Release from the Waste Gas System

     5.2.1      Event Chronology
               On December 17, 1985, between 7:40 and 8:00 p.m., an uncon-
               trciled release of radioactive gases occurred in the waste
               gas compressor cubicle. The plant was at steady-state 75%
               power and the reactor coolant system was at normal operat-
                ing temperature and pressure.
               Repair personnel were logged in on RWP 31377 to perform
               preventive maintenance on the 'A' waste gas compressor
               (WDG-P-1A). The waste gas compressor system was tagged out
               in accordance with the switching and tagging order. Howev-
               er, a decision was made on December 16, 1985 by the shift
               supervisor, shift maintenance foreman and radiological
               controls supervisor to use check valve WDG-V-20 for isola-
               tion from the pressurized vent header.    Isolation valve
              WDG-V-100, which is downstream of the check valve, was not
              closed because preventive maintenance was also being
               performed on that valve.
              A radiological controls technician was assigned to monitor
               the job. A carboy was used to drain the separator tank so
               that any releases would be limited to noble gases, as re-
              quired by the RWP. While drain'ng, an increase was noted
              on the RM-14 monitor. A local gas sample was obtained, and
              results indicated the presence of Xe-123 at 3.73 E-7
              uCi/cc. No further problems were foreseen, so the job was
              continued on the basis of these dos,e rates.
              At 7:40 p.m.,   a strainer was removed from the system and
              prompted an immediate response on radiation monitors. At
              7:45 p.m., monitors RM-A6 (particulate and gas) and RM-A8
              (gas) showed increases. The vent header was checked and a
              small pressure drop was indicated. Steps were taken to
              stop the job and return the system to a safe condition. At
              7:55 p.m., RM-A6 (particulate) was changed out, but the
              monitor continued to rise. Local gas sampling was taken.
              The shift foreman and shift maintenance foreman entered the
              cubicle to determine how to stop the release as the radio-
              logical controls technician was removing the other people
              from the area.    The check valve was determined to be leak-
              ing, so the strainer was reinstalled at 8:00 p.m.; this
              stopped the release.
    5.2.2     Sc_ ope of Review
              The inspectors reviewed the details of the leak and the
              licensee's review of this event to determine:
                           52
      --
            details regarding the cause of the event and event
            chronology;
      --
            consistency of licensee actions with NRC license and
            procedural requirements; and,
      --
            licensee actions to correct the cause of the event.
      The inspector's review of this incident included discus-
      sions with cognizant licensee personnel and review of the
      following documents:
      --
            system drawings;
     --
            CR0 and SF logs;
     --
            switching order 85-1882, dated December 15, 1985;
     --
            administrative procedure (AP) 1044, " Event Review and
            Reporting Requirements," Revision 14, dated June 4,
            1985;
     --
            various radiological data and calculations;
     --
            RWP #31377; and,
     --
            critique meeting minutes.
     The inspectors also attended the radiological investigative
     critique that was held on December 18, 1985.

5.2.3 Licensee Findings / Actions

     The cause of the event was leakage past a check valve that
     was being used for isolation purposes. Immediate correc-
     tive actions were to close the system by reinstalling the
     strainer into the heat exchanger, and closing valve
     WDG-V-100, for further isolation.
     The RM-A6 (particulate and gas) and RMA-8 (gas) monitors
     showed maximum increases from 300 cpm to 2000 cpm, 80 cpm
     to 200 cpm, and 90 cpm to 220 cpm, respectively.     These
     values were below alert setpoints.
     A total of eight people were determined to have some amount
     of contamination, either to skin, clothing, or both mostly
     due to a short lived noble gas decay. The licensee esti-
     mated personnel exposures of aoout 4E-5 millirems from the
     incident, which is significantly lower thari NRC require-
     ments. The amount released to the environment was estimat-
     ed to be less than 0.001 percent of the quarterly limit for
     noble gases.
                                   53
              As part of the licensee's followup actions, this event will
               be presented to other shifts through the use of the required
               reading book. A procedure change request will allow
              WDG-V-100 to be worked on at a more opportune time, when
               the probability of a release will be reduced. Also, pre-
              ventive maintenance procedures for gas compressor work will
              be split up to ensure adequate isolation is provided in the
               future.
    5.2.4     NRC Operational Assessment
              Licensee immediate corrective actions during the event were
              appropriate.    Followup corrective actions from the
              licensee's self-review were also appropriate and reasonably
              thorough. During and after the event, the licensee fol-
              lowed procedures adequately. However, the inspector con-
              cluded that licensee representatives used poor judgement in
              relying on a check valve for isolation purposes. They
              should have completed preventive maintenance on WDG-V-100
              before or after performing preventive maintenance on the
             waste gas compressor; therefore, this valve could have been
              used to isolate the system to preclude the radiological
              release.
    5.2.5    NRC Radiolocical Assessment
             The NRC confirmed the licensee's estimate of activity re-
              leased to be about 1.4 curies over a 54 minute duration.
             Offsite exposure due to this event was calculated to be
             about 1.35 E-3, total dose, based on very conservative as-
             sumptions, compared to the licensee's values of 5.2 E-5
             mrad gamma and 1.2 E-4 mrad beta, derived from the
             licensee's offsite dose calculation manual. Licensee ac-
             tion relative to recovery, radiological controls and evalu-
             ation of personnel exposure were found to be adequate and
             in accordance with regulatory requirements. This release
             constituted less than 0.001*. of the quarterly release limit
             specified in technical specifications.

5.3 Makeup Pump Leak

    5.3.1    Event Chronology
             At 1:26 a.m.,   makeup pump 1A was started to supply normal
             makeup to the reactor coolant system while realigning elec-
             trical power to makeup pump 18. At 1:31 a.m., an auxiliary
             operator reported slight leakage from mechanical seals on
             makeup pump 1A and increased radiation activity levels in
             the makeup pump cubicle.    At 1:35 a.m., auxiliary building
             radiation monitor RM-A6, gas and particulate channels,
             reached the alert level. At approximately 1:38 a.m., the
             inboard mechanical seal on makeup pump 1A failed and water
           -._-- .-                -                    .               _. - ._.    . _ _      __ .                                 , . . _ _ _               . - .

,

                                                                                 54

a

                                        was sprayed onto the walls of the cubicle.                                   The plant oper-
                                         ators restarted makeup pump 18 and secured makeup pump 1A.
                                        Approximately 300 gallons of water was spilled onto the
                                         floor. At 1:42 a.m. the combined fuel handling building
                                        and auxiliary building vent radiation monitor RM-A8, gas
                                        channel, reached the alert level. Based on the fact that
                                        both RM-A6 and RM-A8 were in an alert status, the shift
                                         supervisor declared an unusual event at 1:50 a.m.
                                        The shift supervisor directed that makeup pump 1A be iso-
                                         lated and drained. Station health physics personnel began
                                        to clean up the room.
                                        Both radiation monitors immediately began to decrease; the
                                        RM-A8 alarm cleared at 2:00 a.m. and the RM-A6 alarm
                                        cleared at 2:27 a.m. The licensee decided not to secure

i '

                                        from the unusual event condition since a planned pump
                                        draining evolution had the potential for additional radio-
                                        active releases. At 4:00 a.m., makeup pump 1A had been
                                        crained and the unusual event was terminated at 4:20 a.m.
                                       As a result of the release, nine people were found to be
                                        contaminated. Of the nine, three were found to have actual
                                        skin contamination (two on the skin and one on his hair).
                                        The two with actual contamination on their kin were decon-

<

                                        taminated using soap and water.
                    5.3.2              Scope of Resiew
                                       The inspector reviewed the details of the leak and the
                                        licensee's review of this event to determine:
                                       --
                                                             details regarding the cause of the event and event
                                                             chronology;
                                       --
                                                             consistency of licensee actions with NRC license and
                                                             procedural requirements; and
                                       --
                                                             proposed licensee actions to correct the cause of the
                                                            event.
                                       The inspector's review of this incident included discus-
                                       sions with cognizant licensee personnel and review of the
                                       following documents:
                                       --
                                                             systems drawings

, --

                                                            CR0 and SF logs
                                      --
                                                            applicable RWP and radiological assessment report
                                      --
                                                            critique meeting minutes
                                                                                                                                                                    i

,

 -
   . _ - -           .    ._. _ . _ _ _ . _ . _ . _ _ . _ _ _ . _ . _ _                   _ __
                                                                                                    _ , _ . . _ _ _ _ _ _ , , . _ .             _ . _ . _ _ .
                 -              . - . -               . _ - - _ .              . - . .- __                 -_    __
                                                                55
           5.3.3       Licensee Findines/ Actions
                       The licensee's investigation determined that makeup pump 1A
                       (MU-P-1A) experienced an inboard mechanical seal failure.
                       The seal failure resulted from a loose thrust bearing lock-

l nut. This resulted in the loss of the thrust bearings

                       function, allowing the pump shaft to move axially and to
'
                      cause the seal failure. The locknut had been secured with
                      a set screw, which had loosened allowing the locknut to
                       subsequently loosen. In order to prevent a recurrence of
                      this failure, the licensee dimpled the shaft at the loca-
                      tion of the set screw and applied "Locktite" (permatex
                       sealant) to the shaft and set screw. Radiological releases
                     were within regulatory requirements.
           5.3.4     NRC Operational Assessment
                      Review of licensee actions during the event were found to
                     be appropriate and proper use of procedures was noted. The
                      root cause was appropriately determined to be a failed me-                                             I
                     chanical seal caused by a makeup pump thrust bearing shift.
                     The inspector reviewed the engineering evaluation for the
                     dimpling of the shaft and the application of the sealant.
                    Also, the actual work that implemented the modification was
                    witnessed. The work was found to be adequately controlled,

, supervised, and performed by experienced and knowledgeable ,

                    workers. Quality control personnel also observed the work.                                             '
                    One minor problem arose with regard to the use of Permatex
                     sealant on the thrust bearing housing cap and end plate
                    joints. All three pumps had previously been sealed with
                     Permatex in these areas. During reassembly of the 1A pump,
                     the use of Permatex sealant was not approved by QC; and,
                     therefore, it subsequently leaked minutely during testing.
                    The 18 and IC pumps were made up using an approved sealant.
                    The licensee will review the tasks that used Permatex to
                    determine if it is acceptable.                                         Following the completion of
                    the modification, all three pumps were tested prior to
                    being declared operable. The inspector had no further
                    questions with regard to this matter.
                   During observation of the work being performed on MU-P-1A,
                     it was noted that the installed thrust bearing locknut was
                   made of brass, while the vendor's manual for the pump spec-
                    ified the thrust bearing locknut to be steel (SAE 1020).
                   The licensee contacted the vendor and determined that four
  _- -- -.         . - . _ -    - - . , _ - _ _ - - -              - . - - - _ - - - . .            -    . - - .     --- -
  _   __        _-- -- __ _ __              _ . _ _ _ _  _  _      . _ - _ __ ..__
4
                                 56
           replacement locknuts made of brass, instead of steel as or-             l
          dered in 1974, had been mistakenly shipped. This was at-
           tributed to human error in reading the equipment material
           list; brass is the specified material for the item directly
          belcw the locknut on the material list.       The locknuts in-
           stalled on MU-P-1B and 1C were verified to be made of
           steel.
          An engineering evaluation was performed to justify the use
          of a brass locknut on the 1A pump. This evaluation used

4 the pump manufacturer's calculations using worst case axial j thrust loads; the evaluation showed that the brass locknut

          would not be subjected to shear failure of its threads.

1

          The brass locknut will be replaced with a steel locknut at
the earliest convenient opportunity.
          From the licensee's operational and engineering review, the

, root cause was identified and corrective actions were ,

          appropriate.
    5.3.5 NRC Radiological Assessment

i

          Analyses of the event indicated that the predominant radio-
          logical contributor was noble gas activity; i.e., radioac-
          tive krypton and xenon gas. As a result, about nine people
          in the auxiliary building were contaminated with particu-
          late noble gas decay daughters; i.e., Rb-88 and Cs-138,
          which caused negligible exposure. Workers involved in re-
          covery and clean-up operations received less than 50 mrem
          exposure for the event.
          The spray caused a spill of about 300 gallons of reactor

! coolant which was collected via the floor drain system in

          the auxiliary building sump. Off gasing of the noble gas
          constituents during the event resulted in release of noble
          gas activity through the station vent for about 74 minutes.
          Evaluation of the vent monitors indicated that about 46
          curies of noble gas activity, principally Xe-133, were
          released. Off-site dose consequences of this release were
          calculated to be 3.69 E-3 mrad gamma and 5.97 E-3 mrad beta
          at the site boundary. Such exposure constitutes 0.07% of
          the quarterly limit permitted by the license technical
          specifications; i.e., 5 mrad gamma air dose and 10 mrad
          beta air dose.       These values were independently confirmed
          by the NRC inspector.
1
   --             -   - -    -- ._..         __ _- ._ __. -_                    -.       -.   . .- _ --
                                                         57
                          The licensee's followup and review of the occurrence was
                          thorough and timely. Radiological control coverage was
                          sufficient to rapidly identify the hazard and minimize

'

                          personnel exposure,                The licensee's critique of the event
                          identified areas in which response should be improved and
                          action was initiated to implement lessons learned.
                          No conditions adverse to regulatory requirements were iden-                   i
                          tified in this area.
                                                                                                        1

l 5.4 Conclusion !

                          Operators were responsive to these events with respect to
                          isolating the radiological release and/or following appro-
                          priate plant and emergency procedures.                   The licensee's       i
                          event review or critique was thorough enough to identify

a tne root cause of the events. Appropriate corrective at-

                          tion was taken or planned. Licensee dose calculations were

I conservative and independently verified by the TMI-1 Re- l start Staff. '

      6. Radiation Protection
         6.1 Radiological Program Area Review
              The licensee's program was reviewed against, (1) criteria contained
              in 10 CFR 20 relative to personnel exposure control and radiological                      i
                                                                                                        !
              surveillance, (2) applicable license conditions relative to internal
,
              audits and assessmen+,s and procedure establishment and implementa-
1
              tion, and (3) personnel qualification and training. Additionally,
j             management controls were reviewed.
              Adequate procedures and protocols are established and implemented to
              control personnel exposure both in plant and offsite.                     The licensee
              is consistently conservative with regard to dose assessments, and
,
              generally exercises good judgement in analyzing and assessing events
I             which have the potential to cause increased exposure.
l
!
              Internal audits for the 1935 period were reviewed relative to the
              Radiation Protection Plan. The audits were conducted by qualified
              personnel and exhibited sufficient technical depth to evaluate pro-
              gram performance. Though most audit findings identified in this pe-
              riod were administrative in nature, sufficient technical insight was
              demonstrated.
              However, while this particular audit process is formalized and car-
              ried out in accordance with schedules, there is no assurance that all
4             program areas will receive sufficient review, since the audit scope
              is not tracked.        Rather, a general audit assignment is made and the
!                                                                                                       i
                                                                                                        <
1
 l
i
 i
              ..   .      . __                        -. .. - _ = . -      - -                 - _ - - -               -        . -         - - . .
                                                                                                                                                    L
                                                                        53
 i
 !
 l                              individual auditors decide on the scope and depth of the assessment,
 .                              with management approval. There is no system currently in place that
!
                                tracks audits of individual program elements that can be utilized to
 ;                              verify that the entire program as defined by the Radiation Protection
i
                                Plan is subject to periodic critical review.                             This item will be
                                reviewed in a subsequent inspection (289/85-30-03).
!                               Radiological surveys are performed thoroughly with sufficient detail
j                               to support radiological work. Current surveys are conspicuously
 '
                                posted at the control point to support worker briefings and at indi-
1                               vidual radiologically controlled areas as a reference to actual

I conditions. '

                               Personnel exposure control practices involving RWP usage appeared
                                sufficient to prohibit inadvertent, unanticipated or unplanned per-
                                sonnel exposure, provided personnel conform to established policies
                               and procedures. During this inspection, the licensee identified that
                               an individual inadvertently entered an area requiring an RWP without
j                              such authori:ation, due to misplaced area posting. Immediate and
  '
                               adequate action was taken to assure that the area was adequately con-                                                s
                                                                                                                                                    '
                               trolled and exposure to the individual assessed.                                 In this event, the
                               individual received less than 10 millirem due to                           the occurrence. The

i licensee initiated action to prevent recurrence. Though technically , 1

                               a violation of technical specification 6.13, "High Radiation A eas,"                                                 '
                               this event meets all of the criteria for licensee identified events
                               specified in 10 CFR 2, Appendix C, and will not be cited.
The licensee's training and qualification program was reviewed and
appears sufficient to assure competency and technical proficiency
                               among radiation protection personnel. While actual operating experi-
                               ence is limited in the department, sufficient management oversight
                               and control is exercised in an effort to compensate.
i
                               Management personnel demonstrate a high degree of involvement and
understanding of plant conditions, communicate effectively internally
                               and inter-departmentally, and appear to plan, organize and direct
                               effectively.

! No conditions adverse to regulatory requirements were found in any of

                               the areas reviewed.

! 6.2 Control of Work Activities

The licensee's program for controlling work activities and worker

i

                               exposure was evaluated by interviews with selected members of the
                               radiation protection staff, and revies of the following documents and
                               procedures.
,

i i

    _ _ _ - -    - . -    .-.         . - - . . . -_ _ .              .        , - , . - - . _             - . , . .          .     - - . .
  __                          _ .__ -          - _ _ _ - . - - _ - _ . - _ _ _ _                                              - . .                      -_.--.-__.. -                                       -- .---
i
                                                                                                                      59
4
                                        --
                                              procedure 9100-ADM-4110.04, " Radiation Work Permit"
:                                       --
                                              RWP # 31259, " Remove FS Detector 8-2 from Service," and associ-
                                              ated ALARA review
,
4
                                        --
                                              RWP # 031201, " Change MUF 2A&B and MUF 1A&B," and associated
                                              ALARA review

1 --

                                              RWP # 031202, "Decon Letdown Prefilter Cubicle and Hallway"
                                                                                                                                                                                                                     P

j

                                        --
                                              RWP # 031204, " Remove Broken Filter from Letdown Filter Room"
                                        --
                                              selected radiological surveys associated with the above RWP
                                              packages

.

l
                                       --
                                              selected RWP signature verification and entry-exit times

,

                                       --
                                              the health physics air sampling log book

, The licensee's radiation work permit (RWP) system specifies rcdiolog-

*
                                        ical controls for specific and routine work activities in radiologi-

, cal areas. The inspector reviewed the RWPs mentioned above, along

*
                                       with selected associated documentation and determined that:
                                       --
                                             radiological surveys used in the development of RWPs were gener-
                                             ally of sufficient depth and scope;
l
                                       --
                                             radiological controls outlined in the RWPs were appropriate for
                                             the work being performed;
                                       --
                                             administrative requirements of the controlling RWP procedure (HP

] supervisory review, pre work briefings, etc.) were being com-

                                             plied with;
                                      --
                                             air sampling was performed as required by various RWPs; and,
                                      --
                                             workers wearing respiratory protection on selected RWPs had re-

! ceived required respiratory protection training and fit-testing. , i .

                                      Overall licensee control of work activities and worker exposure was
,                                      found to be adequate. The inspector noted the licensee's method of

l choice for job specific air sampling is to provide lapel air samplers  ;

                                      to the work parties.                                                     This ensures a representative breathing zone                                                          '
                                      air sample is collected and used to calculate MPC hours.
                             6.3 Posting and Area _ Control

a ! The licensee's posting and control of airborne radioactivity areas, 4

                                      contaminated areas, and radiation and high radiation areas was re-
viewed with respect to the following criteria.

} i

                                             Technical Specification 6.12, "High Radiation Area"
                                                                                                                                                                                                                      '
                                      --
>
     - - - - - - - - - _ - -                                          . - - - - - - - . - - - . . , - - , . .,                 ,    - - -
                                                                                                                                          , , . , . , - -- . _ - , . . - - , - _ , - - - . . . . . . , - - -
                    -           -           -            - - - . - - -          -       _-. - - - .                     . - -             - _ - _ -               -
t
!

l

                                                                             60
t

j . l .

                                   --
                                              10 CFR 20, " Standards for Protection Against Radiation"
                                   The licensee's performance in this area was reviewed by the following
,
                                   methods:

1 --

                                             inspector tours of the various radiological work and storage

-

                                            areas

! {

                                   --
                                            performance of independent surveys by the inspector

2

                                   --
                                             interviews of radiation protection supervisory and
                                            technician-level personnel
                                  Housekeeping in the licensee's radiological areas was generally good.

l The inspector noted the licensee has implemented the guidance con-

                                   tained in NRC IE Notice No. 84-82, " Guidance for Posting Radiation
                                  Areas," in that posting has in general been limited to small,
                                  discrete areas around the radioactive source, rather than simply
                                  posting at cubicle doorways. This effort by the licensee to minimize
                                  over posting helps prevent worker desensitization to radiological

'

                                  posting.

i

This inspection effort included tours of the auxiliary building and inde-
                                  pencent survey verification of licensee radiological boundaries. The

j inspector noted during a survey of the mini-valve alley on the 286

                                  foot elevation that a high radiation area posting inside the cubicle
                                  was not appropriate. A "high radiation area" sign and posting is
                                  required to indicate the presence of a high radiation area, i.e. an
                                  area where radiation dose-rates exceed 100 mrem /hr. Consequently,
                                  the boundary and posting for the high radiation area should be locat-
                                  ed outside the area, where dose-rates are less than or at 100

,

                                  mrem /hr, to alert personnel.

>

                                                                                                                                                                    1
                                                                                                                                                                    '
                                  The inspector determined that the radiation field inside the cubicle

i

                                  was non-uniform and that while the licensee's boundary was
                                  adequately placed when dose-rate measurements were made at waist lev-

] el, dose-rates greater than 100 mrem /hr could be measured outside the

'
                                  high radiation area boundary at the head level.

4 Immediately the licensee satisfactorily reposted the cubicle when

                                  informed of the inspector's findings. Subsequent surveys in the cu-

i

                                  bicle and comparison with previous routine surveys indicated that
                                  dose-rate conditions had changed in the cubicle in the interval be-

,

                                  tween the last licensee survey and the inspector survey in the
                                  cubicle.
                                  The licensee indicated that HP technicians are instructed to make
                                  " general area" dose rate measurements by recording the highest
                                  waist-level dose reading in a 360 inch circle. The licensee indicat-

'

!
                                  ed some technicians may have extended this technique to the posting
                                  of radiation and high radiation areas, using waist-level dose rate

I

i

j

  .- ,- . - . - - - . - - - - .         .- . - , - - - .               . - -      - - -             , . - , - - - - - - - - - - , . - - -           - - - - - - .
                                   61
     readings. The licensee indicated that technicians would be notified
     as to the posting problem indicated above and the need to survey fcr
     dose to the whole body and post accordingly. Licensee followup ac-
     tion will be reviewed during a subsequent inspection (289/85-30-04).
     Within the scope of the above review, no conditions adverse to regu-
     latory requirements were identified.

6.4 Recurrence of Noble Gas Contamination of Personnel

     During this review it was noted that occurrences involving the use of
     the auxiliary building floor and equipment drain system to direct
     reactor coolant runoff to the auxiliary building sump of ten result in
     personnel contamination. Such contamination is due to the shortlived
     particulate daughters of the noble gases Xe-138 and Kr-88; i.e.,
    Cs-138 and Rb-88, respectively.
    While individual exposure to this type of contamination is generally
    not significant due to the short decay period of Cs-138 and Rb-88,
    the recurrence of events in which large portions of the auxiliary and
     fuel handling buildings are affected by noble gas activity is not nor-
    mal to the operation of the facility.
    In an effort to understand the conditions that cause extensive noble
    gas migration in the auxiliary and fuel handling building, the
    licensee initiated actions to test floor and equipment drain systems.
    As a result, a drain header has been recently identified as being a
    primary conduit of noble gas through the auxiliary building and into'
    the TMI-2 portion of the fuel handling building.
    In an effort to restrict and control this pathway, suspect drains
    were either incorporated into the loop seal surveillance program,
    sealed or covered. Additionally, action has been initiated to detect
    and seal major leakage points through the Unit 1/ Unit 2 environmental
    barrier.    These efforts should prevent the spread of Unit 1 airborne
    activity to Unit 2. However, noble gas involvement of large portions
    of the auxiliary building due to localized activities such as flushing
    operations, reactor coolant sampling, and component leakage, is still
    not under control and results in the frequent contamination of several
    personnel.
    Though the licensee is investigating various mechanisms that may be
    responsible for this problem, there is no concerted or organized ef-
    fort yet developed to assure the timely completion of investigative
    action items, the analyses of results, and the development of an ef-
    fective resolution.
    This item will be reviewed in a subsequent inspection and is current-
    ly being followed by NRC staf f (289/84-16-01).
                                                                          4
                                                                  .
                    A
                                    .
                                           62

7 '. Emergency Feedwater Pump (EF-P1) Operability

                                                 .
      7.1 Review
    '
            The ilispector assessed the operability of the turbine-driven emergen-
            cy feedwater pump based on a revtew of licensee maintenance (preven-
             tive and corrective) and surveillance activities to verify that:
            --
                  procedures required by Technical Specifications (TS) 4.2.2 and
                  4.2.1.1 are'being properly implemented;
            --
                  applicable procedures have the properiformat and technical con-
                  tent in accordance with the ASME BoileFarM Pressure Vessel
                  Code, Section XI, Subsection IWP, and applicable sections of
                  ANSI N18.7-1976;                                    
            --
                  surveillances and preventive maintenance (PM) were conducted at
                  the proper frequency; and,
           --
                  machinery history records and related surveillance and PM
                  records were retrievable.
            In addition to discussions with cognizant licensee personnel (mainte-
           nance, operation, and en;ineering), the inspector reviewed selected
           portions of the folicwing'iicensee documep p and records:
           --
                  surveillance procedure (SP) 1300-3G A/B, " Turbine Driven mer-
                  gency Feedwater Pump Functional Test and Valve Operability
                  Test," Revision 20, dated November 13, 1985, including data ob-
                  tained on December 11, 1985, November 13, 1985, October 13,
                  1935, and September 15, 1985;
                                       '
           --
                  PM' procedure 1410-P-3, " Lube 011 Change,'! Revision 6, dated Feb-
                  ruary 2, 1935;
           --
                  selected job tickets from machinery history files, numbers
                  C8969, CE756, CF763, and CH760 between the period of January 1,
                  1973 to November 5, 1985; and,
           --
                  Worthington Pump International Technical Manual 2134-EIC, "WT
                  Pumps" and Technical Manual W-9C, " Turbine."
    7.2 Findings
           On December 16,1985. EF-P1 was out of service to test a new governor
           valve controller.     This controller was bsing tested to determine if
           it would prevent the relief valves on the steam line to the EF-P1
           turbine from lif ting durir,g the start sequence and if it could ade-
           quately control EF-P1 during operation. The inspector reviewed tag-
           ging order 85-1881 that was used to place EF-P1 out of service. The
           inspector determined that appropriate valves were tagged locally and
           in the control room and appropriate breakers were opened.
                                             _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___

l

                                        63

l

While the licensee was testing the new controller, the inspector ob-

!

          served good work practices, except for two instances when workers
          used the limitorque operator for MS-V-10B as a stepping point. Dur-

,

          ing testing, the controller did not perform satisfactorily and the
          licensee replaced the new controller with the old controller. In

'

         order to return EF-P1 back to service, SP 1300 3G A/B was used. The
          inspector reviewed this package and no discrepancies were noted.
         The review of machinery history on EF-P1 revealed no major problems

i

         over the last twelve years, except for a bearing replacement during

j the spring of 1985. This history file provided a useful summary of

         work activities on the turbine-driven EFW pump. The job ticket
         records were retrievable using the licensee's microfiche and micro-
          film systems.
         Preventive maintenance procedures appropriately reflected vendor ret-
         ommendations to change lubricating fluids at six-month intervals on
         both the pump and turbine. The pump manual also recommended that the
         pump should not be routinely disassembled; this should only be per-
         formed when there is a problem with the pump. The licensee is plan-
         ning to follow this recommendation.
         Surveillance and preventive maintenance procedures were current and
         being conducted at the proper frequency in accordance with technical
         specifications.     The records of these tests were retrievable. SP
         1300 3G A/B was found to meet all applicable requirements of Subsec-
         tion IWP, Section XI of the ASME Code.
    7.3 Conclusions
         The inspector concluded that the licensee properly tagged out of ser-
         vice EF-P1 and appropriately returned it to service. Licensee
         records were well kept and reflected applicable procedures that were
         being properly implemented. The licensee is continuing to follow the
         recurring problem with the EF-P1 steam relief valves.                   Pending
         satisfactory resolution of this issue, in place surveillance and pre-
         ventive maintenance procedures should provide adequate reliability
         that the turbine-driven emergency feedwater pump will be operable
         when needed.
 8. Non-Licensed Staff Training
    8.1 General
         The purpose of this portion of the inspection was to assess the ef-
         fectiveness of the licensee's non-licensed training. As a represen-
         tative sample, the inspectors chose the training programs for
         instrumentation and control (I&C) technicians, electrical and mechan-
         ical maintenance personnel, and auxiliary operators (A0s). The in-
         spectors noted that the licensee is in the process of obtaining INP0
                                                   _ _ _ _ _ _ _ _ _ _ _ _
                                      64
       accreditation for these training programs. The effectiveness of the
       existing program was determined by reviewing the following
       activities:
       --
             monthly reactor protection system surveillance by the I&C
             technicians
       --
             shif t turnover for A0s (0700 twice,1500 twice, 2300 twice)
       --
             corrective maintenance (CM) for hydrogen analyzer by I&C techni-
             cians (CM-1430-HA-2, paragraph 6.10)
      --
            A0 activities on all three shif t (changing over the hydrogen
             supply to the makeup tank and taking secondary plant readings)
      --
            minor maintenance by mechanical maintenance personnel (mainte-
             nance of leaking valves in accordance with CF 498)
      --
             vibration test on main steam drain pipe by electrical mainte-
             nance staff
      --
             repair work on water screen
      --
             troubleshooting for the AH-E-12 fans circulating systems (pre-
             liminary action to determine if a CM or a work order (WG) is
             required)
      --
            welding activities (DF 2A&B piping in accordance with WO-C-7409)
      These activities were selected from day, eyet*ig, and midnight shifts.
      The problems associated with the power operated relief valve (PORV)

, surveillance on October 25, 1985, was used as an example of personnel

      error.
 8.2 Details of the Review
      For each of the job functions identified in Section 8.1, the inspec-
      tors reviewed the established training program, implementing proce-
      dures, qualification, and experience of personnel, qualification and
      training of instructors, quality of on-the-job training, and the ef-
      fectiveness of training as evidenced in daily activities. The com-
      ments and evaluations from the trainees, line supervisors, and
      instructors were also reviewed to establish how this feedback was
      factored into future training. Lessons learned from the events at
                              ~
      the licensee's facilities, as well as other facilities, were also
      reviewed to detern.ine how such information was factored into the
      training program. The management and QA involvement in the training
      area was assessed to determine their effectiveness. No violations
      were identified. The observations in each of the review areas are
      given below.
                       -- _--
                                              _ _ _ _ _ _ _ _ _ _ _ _
                            65

l , 8.2.1 Observation of Work Activities l

       The inspectors witnessed the work activities identified in
       Section 8.1 above. The activities were conducted in accor-
       dance with the procedures. The personnel were knowledgeable
in the requirements of the procedures and technical specifi-

l cations. Experienced personnel were providing adequate J guidance to inexperienced personnel. All of the activities l witnessed were conducted satisfactorily.

       Two situations, the monthly reactor protection system sur-
       veillance and the followup of the PORV surveillance error,
       are discussed in detail. For the reactor protection system
       surveillance, the inspector witnessed the interaction be-
       tween experienced and inexperienced personnel. The experi-
       enced technician read the procedure requirement and the
       inexperienced technician performed the action. Adequate
       time was provided to the inexperienced technician to con-

7 duct the action. The experienced technician was patient to

       let the inexperienced technician learn from his mistakes.
       For example, while performing step 8.5.14 of procedure
       1303-4.1 (revision 47), the inexperienced technician con-
       nected the digital voltmeter to the test jack of the auxil-
       iary power supply instead of the power range detector power
       supply.    The inexperienced technician sensed a concern when
       he had to over adjust to bring .Se output within tolerance.
       At this juncture, the experier ;e technician stopped the
       procedure and initiated the i v'stigation. The foreman
       brought the lead foreman to th' work area to provide fur-
       ther assistance. In step 8.8.8 of the same procedure, the
       technicians noted that the pressure / temperature bistable
       trips were not within tolerances.     In this case, the I&C
       supervisor came to the work area and assisted the personnel
       in identifying and correcting the concern.                     The problem was
       caused by an above-normal zero/ gain setting on the signal
       converter. The problem was corrected and the supervisor
       instructed the technician to monitor the output from the
       signal converter carefully for potential problems in the
       future.
       The inspectors also reviewed the actions undertaken by the
       I&C group to preclude the problems developed during ana
       after the PORV surveillance test described in paragraph
       8.1 above. The maintenance department issued a verbal or-
       der to require that all techr.ical specification related
       surveillances are to be conducted by senior personnel. The
       inspectors reviewed the log for monthly surveillances of
       RPS channels. Since October 25, 1985, these surveillances
       were conducted by senior personnel. The inspectors found
       the activities to be conducted in a competent manner by
       qualified and properly trained oersonnel.
                                         66
           8.2.2     Training Policy and Programs
                     Procedure 1000-POL-2600.01, Revision 0-00, dated April 15,
                     1985, established the licensee's training policy. This
                     policy : tresses items such as the basis for training,
                     commitment to training, on-the-job performance, and effec-
                     tiveness. It also established the role of the Training
                    Advisory Council and the commitment to pursue and maintain
                     INPO accreditation. This policy is implemented through
                     system-wide procedures. The inspectors reviewed the imple-
                    menting procedures listed below as a representative sample.
                                 Documents Reviewed
 Number             Title                                     Revision Date
 6211-PGD-2612.01   Auxiliary Operator Training               5-00      8/1/85
                    Program TMI-1

'

 6210-ADM-2621.01   Maintenance Training Program              3-00      7/20/84
                    TMI-1/TMI-2

1

 6210-ADM-2621.02   Maintenance Training Instructor           2-00      10/24/84
                    Certification / Qualification
                    Training Program
 6210-ADM-2621.03   Maintenance Indoctrination Training       1-00      5/17/85
                    Program TMI-1 and IMI-2
 6210-ADM-2604.03   Control of Examinations Units 1/2         0-00      3/1/85
 6210-ADM-2620.01   Revision Review / Required Reading        3-00      11/1/85
                    Book for Technicians and Support
                    Training Instruction
 6210-ADM-2610.02   Operator Training Instructor             01         8/23/82
                    Indoctrination / Qualification
                    Training Program
 6200-ADM-2682-09   Standard Evaluation While In Training    0-00       4/15/85
 6200-ADM-2682-10   Trainee Evaluation Once Back              1-00      9/13/85
                    On-The-Job
 6200-ADM-2682-11   Program Evaluation                       0-00       4/15/85
 6200-ADM-2682-12   Course Evaluation                        0-00       4/15/85
 Maintenance Department Standing Orde s Nos. 17 and 18
                                                                                 l
                      67
   The training for non-licensed personnel consists of both
    formal and on-the-job training. The formal training is
   provided at the training facility and the laboratory. It
    includes discussions of theory, hands-on operation, and
   maintenance of generic components such as pumps and valves.
   At present, the formal training is conducted in classes
   containing all levels of personnel. The instructors pre-
   pare the lessons for the persons with average experience.
   As a result, the formal training tends to be boring for
t
   senior staff and difficult for the entry-level personnel as
   determined through inspector interviews. This is identi-
   fied as an area of concern by both the instructors and
   trainees.   The licensee's self evaluation report identified
   similar problems.
   Training and development educational procedures and job
  descriptions for instructors of various grade levels are
  developed by the Corporate Human Resources Department.      The
   inspector reviewed the training and qualification records
  of the maintenance and A0 instructors. The instructors'
   files were complete and current. The files contained eval-
  uations by peers, supervisors, managers, and Corporate spe-
  cialists.    The inspector reviewed the evaluations by the
   students and noted that the comments are reviewed and cor-
  rective action is taken.     In one case the instructor re-
  ceived additional training in a specific area.
  The inspector reviewed the A0 Crew Required Reading Book
  index. The A0s signed off that they have read items such
  as IE Notices, significant events at TMI-I and INPO
  reports.
  An Operator Training Work Request form is submitted by per-
  sonnel requesting additional, modified or new training.
  Request form 84-01 regarding additional limitorque valve
  training was submitted by an A0; he is now being trained in
  response to his submittal.
  The training program for non-licensed personnel is expected
  to change considerably in the future due to INP0 accredi-

, tation and an automatic mode of progression for technicians

  and maintenance personnel. The automatic mode of progres-
  sion is in effect for I&C personnel.     However, the electri-
  cal and mechanical maintenance personnel have not ratified
  this option in the union contract.     This option will be
  considered for union ratification in the Spring of 1986.
                                                                   ,
                                                                  '
  The licensee has completed the I&C job and task analysis
  required for the INPO accreditation. This analysis was
  done by an outside contractor. An on-the-job training pro-
  gram was being drafted at the time cf this inspection.     The
  licensee has completed a self evaluation in the I&C area
                                                    68
                              and the report was being drafted for submittal to INPO.
                              The inspector reviewed the licensee's activities and deter-
                             mined that the licensee is progressing towards INP0 accred-
                              itation. The licensee intends to resolve all concerns
                              identified in the self evaluation report by March 1, 1986.
         8.2.3               Training Audits and Evaluations
                              In addition to direct observation of the effectiveness of
                              training through the conduct of work, the inspectors inter-
                             viewed at least one experienced and one inexperienced per-
                              son from each work group for each shift. The interviewees
                             were complementary to the training program and instructors.
                             The inspectors discussed student and industry experience
                             feedback with instructors. The instructors went over the
                             lesson plans with the inspectors and demonstrated the depth
                             of preparation.      In new areas, the instructors spent up to
                             eighteen hours of preparation for one contact hour of
                             classroom instruction. The instructors also demonstrated
                             that the comments from trainees and line supervisors were
                             incorporated in the lesson plans in a timely manner. The
                             instructors provided specific lesson plans to show how they
                             incorporated industry experience gathered from NRC bulletins
                            and INPO documents in such lesson plans.
                            The quality assurance staff conducts routine audits in
                            training and review of the effectiveness in audits for
                            maintenance.       The inspector reviewed QA audit reports
                            S-TMI-85-04 (Training) and S-TMI-84-01 (Maintenance) and
                            noted that these audits were indepth and technically ori-
                            ented. QA personnel demonstrated good knowledge in the
                            requirements of non-licensed training and industry practic-
                            es for maintenance and calibration. In addition to the
                            audits, OA monitors the training and the activities con-
                            ducted by trained personnel. The findings from the audits
                            and monitorings are forwarded to various levels of manage-
                           ment for actions and feedback. The findings are also
                            trended regularly to identify and correct potential
                            problems.
                           The line supervisors actively participated in training ef-
                            forts. Annual training requests were provided to the
                            training personnel in a timely manner.       Managers and super-
                           visors monitored the quality of instruction through occa-
                            sional class attendance. Some line supervisors expressed
                            reservations when instructors signed-off practical factors
                            for technicians and mechanics.
                           The inspectors noted that several practical factors for
                           maintenance personnel were signed off by the on-the-job
                           training (0JT) coordinator on the same day. In discussions

. - _ - _ _ - _ - _ _ . .. . _ _ _ __ __ __ -

-

                                                                        69
                              with the trainees and DJT coordinators, the inspector
                               learned that the date used does not necessarily imply that
                              the specific practical factor was conduct 9d on that day.
                              Certain practical factors go on for weeks under the DJT
                              coordinator's cognizance. The date signed merely indicates
                              that the DJT coordirator reviewed the effort on that day in
                              accordance with Maintenance Department Order No. 17.                                        This
                              order allows for the coordinator's evaluation of those in-
                              dividuals who attained the required skill level through
                              previous experience.                         The coordinators and the trainees
                              indicated that the existing practical factors records do
                              not always adequately reflect the extent of training re-
                              ceived.    The inspector reviewed several oractical factors.
                              In the mechanical area, it is possible to complete several
                              practical factors on the same day.                                  In the electrical area,
                              when the practical factors were signed off on the basis of

. previous work experience, it was not always possible for

                              the trainee or the coordinator to recall the job ticket
                              number or the component designators used for such sign-
                              offs.    This was discussed in detail with licensee represen-
                              tatives and they acknowledged the inspector's observation.
                              The adequacy of the records for on-the-job training will be
                              reviewed in a future NRC inspection (289/85-30-05).
          8.3 Conclusions
                  Within the scope of this inspection, the licensee's training program
                  was effective and is geared to improve on-the-job performance with
                  management support and commitment. QA is actively involved in train-
                  ing. The personnel were knowledgeable in the work and procedural
                  requirements and conducted the activities with care. When faced with
                  problems, the personnel demonstrated the ability to take conservative
                  measures and seek help. In brief, with the exception of certain
                  records-related problems and licensee identified areas of concern,
                  overall, the non-licensed training program was implemented and main-
                  tained in accordance with license requirements and applicable indus-
                  try standards.
       9. Startup to Power Operation Review
          During the inspection period, the staff reviewed selected portions of the
          licensee's maintenance and surveillance and startup testing programs to
          assess the readiness of the plant for startup and release from the final
          power escalation test hold point. The selected areas inspected included
          outstanding licensee identified items in the surveillance, maintenance and
          startup test areas. The objective was to identify equipment operability
          problems that could adversely affect safe operations of the facility.                                               The
          startup testing area was reviewed as documented in paragraph 4.
;
                                            - - - - - - , - - _ - - . .               . - - - - -          . - - .  . - - - -
                                                                                                                        -
  ,. -    - - - -       . - ,   .   --                                             ,
                                         70
      The inspector reviewed selected portions of the licensee's applicable cor-
      rective action tracking systems to determine if any adverse condition for
      safety-related equipment operability existed. The inspector's review in-
      cluded tracking systems for open maintenance job tickets.    The inspector
      reviewed the open job tickets and discussed all work that had been classi-
      fied as priority one, two, and three. Of the priority one, two, and three
work, the inspector determined that the work required by these jobs would
      not have an adverse affect on the plant safety if not performed prior to
      returning the plant to operations.
      Also, the licensee maintains a system for E&Ds associated with surveil-
      lance test procedures in order to identify and track procedure and hard-
     ware problems identified during performance of the tests. The
      surveillance test coordinator (STC) has placed a summary of unresolved
      E&Ds on a computer system and periodically reviews a computer printout to
      ensure that E&Ds are ultimately resolved.
      Prior to the restart of the reactor subsequent to the turbine trip test,
      the inspector requested a computer printout of open surveillance test
      E&Ds.   The inspector along with the STC and an operations engineer re-
     viewed each item listed on the printout. No open test exceptions or defi-
     ciencies were identified on the computer printout which would have
     precluded restart of the plant.
     The inspector asked wnether outstanding E&Ds were routinely reviewed prior
     to any reactor startup.     The operations engineer stated that enclosure 1,
     " Plant Critical Check List (Shutdown greater than 24 hours) " and enclosurc
     2, " Plant Critical Check List (Shutdown less than 24 hours)," to operating
     procedure 1102-2, " Plant Startup," require the verification of the adequate
     performance of numerous surveillance tests. As 'ch test is verified,
     each exception or deficiency which is unresolved must be reviewed to
     assure that surveillance acceptability is not affected. The inspector
     reviewed enclosures 1 and 2 to procedure 1102-2 and observed the verifi-
     cation of surveillance tests and had no further questions concerning this
     area. There were no E&Ds open that would preclude startup after the
     turbine trip test.
 10. Steam Generator Mechanical Cleaning
     Between January 7-9, 1996, TMI-1 Restart Staff inspectors observed the

,

     water slap process demonstration and test program at Lynchburg, Virginia,
     with the objective of understanding the process and familiarizing them-
     selves with the test program. The water slap process involves accelerating
     a column of water toward a tube support plate at a velocity sufficient to
     dislodge accumulated scale or corrosion products from the spaces between
     tube and support plate surfaces.     The test program was to establish that
     the steam generator integrity would not be compromised by process damage
     to components such as tubes, tie rods, tube support plates, and tube-to-tube
     sheet attachments. The testing included multiple applications of the
                                        71
   process to a full scale mockup up to the fourth support plate. Process
   transients such as pressure, stress and tube or tube support acceleration
   were measured.
   From these measurements, stress values of components were established
   for comparison to the ASME Code, Section III, NB, 1983 edition. The
   testing conducted to date indicates that stress values are signifi-
   cantly below the ASME code allowable levels.                   The testing and evalua-
   tion of data are expected to be finalized by late February 1986 and
   documented in a safety evaluation.
   The NRC inspectors observed testing in progress, examined equipment
   in use and reviewed portions of previous safety evaluations that were
   applicable to use of a similar process. The test program was per-
   formed with calibrated sensors and equipment and was noted to be
   carefully planned and performed.
   Discussions with utility personnel indicated that the process was
   successful when previously used.

11. Licensee Action on Previous Inspection Findings

   Tne inspector reviewed licensee action on previous inspection findings to
   ensure that the licensee took appropriate action in response to the find-
   ings or by self-initiative, and that the licensee's action was timely.
   11.1 {0p5 n) 'nspector Follos Item (289/83-26-03): Temperature effects                 on
        RM-L10. Since a question still remains relative to temperature ef-
         r
           ect on RM-L10 the licensee has taken or will take the following
        actions:
        --
               The RM-L10 set point has been reduced by 10% to compensate for
               the expected decreased performance of the detector with increas-
               ing sump temperatures.
        --
               A work order has been initiated to modify RM-L10 with a thermom-
               eter device that will cause increased voltage as a function of
               temperature to automatically compensate for decreased efficien-
               cy; such modification will be made pending the success of test-
               ing by the vendor.
        --
               Procedural modifications are being considered relative to taking
               RM-L10 out of service in favor of composite sampling when the
               reactor is shutdown and the auxiliary boiler is expected to dis-
               charge to the turbine building sump.
        Operatior - 1 data so far indicates that turbine building sump tempera-
        tures may not exceed the design specification for the detector. The
        licensee will continue further monitoring of the system.
                              ._           - _ _ _ . - _ - _ . ._       .
 l                                               72
    11.2 (Closed) Inspector Follow Item (289/84-18-01): Licensee to review
         the applicability of using pressurizer uncompensated water level in
         the reactor coolant system leakage calculation.                               The licensee com-
         pleted that review and decided not to use the uncompensated pressur-
          izer water level signal in the computer calculation for reactor
         coolant system leakage. The licensee determined that the gain in
 ,
 '
         accuracy was only 0.05 gpm and, accordingly, this gain in accuracy
         did not warrant major procedural and software changes.
         Since the use of compensate water level introduces only a + 0.1 gpm
         error in the calculation, the inspector considered the licensee's
         leak rate calculation is acceptable.

'

   11.3 (0 pen) Inspector Follow Item (289/84-18-02):                              NRC staff to review
         applicability of the evaporator loss term in the reactor crolant
         system leak rate calculation.              By internal memorandum, the Office                      of
         Nuclear Reactor Regulation advised Region I that the evaporative loss
         term should either be recalculated to a new baseline number or delet-
!        ed since the current value introduced a negative unidentified
         leak rate which was unrealistic. Concurrent with that determination,
.
'
         the licensee decided that a readjustment of the evaporative loss term
         was appropriate. A licensee procedure change was reviewed and ap-

1 proved to incorporate the licensee's decision in this matter but the

         computer program revision still need work.                   The licensee committed to
 ,       revise the evaporative loss term to zero and to implement necessary
'
         procedural and software changes by January 31, 1986.
I
   11.4 (0 pen) Unresolved Item (289/85-19-02): Licensee to review steam
         generator primary to secondary leak rate actions to factor in experi-
         ente gained as a result of the_ power escalation program. Based on
         TMI-1 staff review, the leakrate Calculation was relatively stable
        despite transients on the plant.               It appears that the limit for
         shutdown 6 gph (gallons per hour) above baseline (0.5 gph) is
         realistic. However, current procedural actions call for extended
        evaluation of the leakrate for 6-12 gph above baseline. This extended
        evaluation period appears to be no longer necessary. The licensee
        committed to review this matter and issue appropriate procedure
         revisions by April 1, 1986.
   11.5 (0 pen) Unresolved Item (289/85-22-02):                   Licensee to resolve problem
        with steam relief valve actuation upon initiation of the turbine
        driven emergency feedwater_pu_mp. Details of licensee actions are
,
        discussed in paragraph 4.3.2.2. The licensee is committed to provide

!

        a fully automatic emergency feedwater initiation system by the
        startup af ter the next refueling outage (approximately rpril 1987).
   11.6 (0 pen) Unresolved Item (289/85-25-05): Licensee to resolve prob.l_em
'
        with continuous actuation of steam _ generator safety valve on high
        power reactor trios. Details of licensee actions are discussed in
        paragraph 4.3.1.2.2.              The licensee committed to having a plan for cor-
        rective action and implementation schedule by the end of the eddy
        current outage (approximately April 1986).

,

                    . , - _ , , . _ . _ .            _      , . -      ,__.._-.-. - __            _ . _ _ _
 ,
1
                                                73
         11.7 (0 pen) Unresolved Item (289/85-25-06): Licensee to review and
                  provide a response letter to NRC Inspection Report 50-289/85-25
                 with respect to the discarding of a test exception and deficiency

,

                  record. The licensee committed to provide the response letter by
'
                 Janu_ry 31, 1986.
!        11.8 (Closed) Unresolved Item (289/85-26-04): NRC staff to review
                  licensee assessment relative to dose effects of leakage from makeup
'
                 pump (MU-P) 1A. The licensee has completed investigation of anoma-
                  lous releases due to problems encountered in the maintenance and op-
                 eration of MU-PIA. The following occurrences were reviewed and found
                 to be acceptably evaluated.

,

                                                       Activity             Fraction of

.

                 Date             Event                Released            Quality Limit
                 10/28/85         Maintenance           0.7 Ci                0.0086%

i problem causing

                                  150 gal. spill
                 12/30/85         Operation            46.3 Ci                0.07%
                                  problem causing
                                  300 gal. spill
                 Additional details in this report relative to recurrence of noble gas
                 contamination are in paragraph 6.
       11.9 (Closed) Unresolved Item (289/85-27-02):               Licensee to evaluate high
                 steam generator water level limit with respect to decreased heat
                 transfer efficiency. The TMI-1 Restart Staff review of licensee ac-
                 tion is documented in NRC Inspection Report 50-289/85-28 but this
                 item number was inadvertently missed from being closed. It is ad-
                 dressed in this report for administrative purposes although the high
                 limit is no longer currently needed (see paragraph 4.2.2.1).
       11.10 (0 pen) Inspector Follow Item (289/84-16-01):             Licensee to balance
                 auxiliary / fuel handling building ventilation.        Based on a review of
                 radiological incidents (paragraph 4) it appears that the leaving of
                 the ventilation system in an unbalanced condition has contributed to
                 the spread of noble gas out of potentially contaminated or contami-
                 nated areas resulting in short-lived daughter product contamination
                 of personnel. Additional details are in paragraph 6.4.
   12.  Exit Interview

i The inspectors discussed the inspection scope and findings with licensee

        management at a final exit interview conducted on January 10, 1986.                      In
        addition to the testing program status meeting of December 17, 1985, in-
        terim exit interviews occurred on: December 20 1985 (Non-licensed train-
        ing); January 8, 1986 (Startup Test Program); and January 9, 1986
         ,-- - -             . -,                  -    .- .- . ._                   . . _ _ _ -    . _ _ . -
                                         74
(Radiation Protection). The following licensee personnel attended the
final exit meeting:

J. Colitz, Plant Engineering Director, TMI-1

T. Hawkins, Manager, Startup and Test, Technical Functions
H. Hukill, Director and Vice President, TMI-1
C. Incorvati, TMI-I Audit Supervisor, Nuclear Assurance
B. Leonard, Operations Training Manager
R. Masoero, Engineer, Plant Analysis
R. Neidig, TMI-1 Communications

M. Nelson, TMI-1 Review Program Supervisor S. Otto, TMI-1 Licensing Engineer

L. Ritter, Administrator II, Plant Operations, P11-1

M. Ross, Manager, Plant Operations, TMI-I D. Shovlin, Manager, Plant Maintenance, TMI-1 P. Sinegar, Administrator II, Manager, Maintenance M. Snyder, Preventive Maintenance Manager C. Smyth, TMI-1 Licensing Manager R. Toole, Operations and Maintenance Director, TMI-1 The exit meeting was also attended by S. Maingi, a nuclear engineer repre- senting the Commonwealth of Pennsylvania. The inspection results, as dis- cussed at the meeting, are summarized in the cover page of the inspection report. Licensee representatives indicated that none of the subjects dis- cussed contained proprietary information. Unresolved Items are matters about which information is required in order to ascertain whether they are acceptable items, violations, or deviations. Unresolved item (s), discussed during the exit meeting, are documented in paragraphs 2.2.4, 4.3.1.2.2, 4.3.2.2, 6.4 and 11. Inspector Follow Items are matters which were established to administra- tively follow open issues based on inspector judgement or on licensee / staff commitments prior to the TMI-l restart. Inspector follow item (s), discussed during the exit meeting, are documented in paragraphs 6.1, 6.3, 8.2.3 and 11.

                                   -- . - _
                               _

4

                                            ATTACHMENT 1
                                    Startup and Testing Meeting
                                   December 17, 1985 - 2:00 p.m.
      Licensee:
     W. Bloomfield, Nuclear Safety Engineer (IOSRG)
     J. Carroll, Jr., TMI-1 Startup and Test Director, Technical Functions
     J. Colitz, Plant Engineering Director, TMI-I
     E. Hammond, Nuclear Safety Compliance Committee
     R. Harding, TMI-1 Licensing
     T. Hawkins, TMI-1 Startup and Test Manager, Technical Functions
     H. Hukill, Director & Vice President, TMI-1
     M. Knight, TMI-1 Licensing Engineer
     R. McGoey, TMI-1 Licensing
     R. Meyer, Nuclear Safety Compliance Committee
     R. Neidig, TMI-1 Communications
     J. Pearce, Senior Engineer I, TMI-1
     M. Sanford, Mechanical Systems, Technical Functions
     C. Smyth, TMI-1 Licensing Manager
     R. Toole, Operation and Maintenance Director, TMI-1
     NRC:
     L. Bettenhausen, Chief, Operations Branch
     A. Blough, Chief, Reactor Projects Section lA
     N. Blumberg, Lead Reactor Engineer
     R. Conte, TMI-1 Restart Manager
     W. Kane, Director, TMI-I Restart Staff
     J. Thoma, Project Manager, PWR Project Directorate #6, NRR
     P. Wen, Reactor Engineer
     State Representative:
     W. Dornsife, Department of Environmental Resources, Commonwealth of Pa.
     S. Maingi, Nuclear Engineer, Commonwealth of Pa.                         ,
 _..
                  -.       . _ _ _    _ _ ,  __       . _ _      __ _ _ _ . _
                                             -.                  .                                   -. . _ . - . .                   . _ --
                                                                                                                                                               --  -             -   - -   . -     -

"

  ,
                                                                                                                                                                              ATTACHMENT 1

. $ d

                                                                                                                      NRC MEETING ON TMI-1

'

                                                                                                               STARTUP AND TEST PROGRAM

i AGENDA - DECEMBER 17, 1985 AT TMI-l

               1.                   Introduction                                                                                                                     R. J. McGoey

.

              2.                   Overview and 0TSG Crud Phenomenon                                                                                                 J. J. Colitz

l.

,
             3.                   EFW Turbine Driven Pump Safeties                                                                                                   M. Sanford
                                                 Discussion
                                                                                                                                                                                                               .
r
             4.                   Main Steam Safety Discussion                                                                                                       M. Sanford

I

             5.                   Conclusion                                                                                                                         R. J. McGoey

.

                                                                                                                                                                                                               I

i

                          a
            2153f
:

1

    . _ . .  . _ _ - - - . _ _ _ _ _ - _ _ , , . _ _ , . . . _ _ _ . - , _ _ _ _ . , _ . _ _ , . . , _ . . , _ . . . _ _ _ _ _ _ . _ _ _ , . . _ . _ _ . _ _ . . .                             . _ - - . . . -
                                                                                                                                                                           .
                                                                       POWER ESCALATION TEST SEQUENCE

Perf. TP 800/1 Perf. TP 800/1 Perf. TP 800/1 Perf. TP 800/1 Perf. TP 800/2 Perf. TP 800/9 Prerequisites

                                                                                                                        Reactor Trip       EFW Pump Auto             for

CPFPET Increase-> CPFPET Increase 4 CPFPET Increase

 Power to 80%                              Power to 90%   Power to 95%
                                                                                      >'     Increase
                                                                                           Power to 100%
                                                                                                                    ^?     "     $$ ot
                                                                                                                                       _3   Start Test
                                                                                                                                                           4      Flag 4
                                                                                                                        Tu         Tdo
       l                                         l               l                                                             l

Perf. TP 849/1 Perf. TP 800/3 Perf. IP 800/5 Perf. TP 885/1 RP 1550-08 and Perf. TP 835/2

ICS Tuning at                              Thermal Exp.  Unit Load Steady -
                                                                                   TG Ops.      -
                                                                                                   SP 1301-9 8 Con ->  Turbine Bypass
     Power                               Checks for Hgr.   State Test               Test             Power Dist.          Valve Test
       I                                         I               I                                                             I

P:rf. TP 836/1 Perf. TP 849/1 Perf. TP 846/1 Loose Parts

 FW Sys. Ops.                               Main Steam     ICS Tunin9     ]Perf.TP800/3
                                                                              Thermal Expan.    -
                                                                                                    Incore Thermo- 9   Vibration Moni-
  rnd Tuning                              Safety Valves     at Power        lChk. for Hanner       couple Ops Test       toring Data
                                                                             Perf SP 1302-1.1       Perf. TP 800/1
                                                                          -
                                                                                Power Range     -
                                                                                                          Plant    3
                                                                                   Calib.             Performance
                                                                              Perf. TP 800/5           LM-29 High
                                                                          -
                                                                             Unit Load Steady   -
                                                                                                       Rad Noise   @
                                                                                State Test            Measurement
                                                                             Perf OP 1103/16       Perf TP 200/1.3
                                                                          -
                                                                               Heat Balance     -
                                                                                                   8 Sta Feed Wtr  9
                                                                               Calculations        Sheli Side Test
                                                                              Perf. TP 836/1          JI #C-7563
                                                                          -    FW Sys. Ops.     -    Acception to  3
                                                                                and Tuning            SP 1302-5.4
                                                                              Perf. TP 849/1           RP 1550-05
                                                                          -
                                                                                 ICS Tuning     -
                                                                                                     React. Coeff. 3
                                                                                    100%                at Power
                                                                                SP 1301-9.5            RP 1550-09                                        : RESTART LICENSING
                                                                          -     Reactivity      -
                                                                                                      Unit Acceo-
                                                                                                        ance Test
                                                                                                                   9                                           CONDITION
                                                                                   Anomaly
                                                                                SP 1303-1.2              Perform
                                                                          -
                                                                                Rx. Coolant     -
                                                                                                         Neutron
                                                                                                         Surveys
                                                                                                                   )
                                                                                 Flow Surv.
                                                                                 R. C. Flux           Loose Parts                                                            23
                                                                          -                     -
                                                                                                   Vibration Mont- 3                                                         *
                                                                                    Flo"              toring Data                                                            $
                                                                                                                                                                             C
                                                                                                                                                                             i
                                                                                                                                                                             $
                                                                                                                                                                             -
                                                                                                                                                                             a
           _ _ _ _ _ _ . _ _ _ _ _ _ _ _             _
         '
                                                                                                                                  ATTACitMENT 1          ,
  .
                                                     .

I Longitudinal Section of the OT5C

                                                                                         i                                                               l
                                                                                                                                                         !
                                                                                           l_
                                             *
                Primary inlet
                                                                             V
                      Tubesheet
       *
                .                                                                                                         Primary Head
                    ,
-
                  .                  , . -
                                             \      f                                                  D4         ,
                                             s                                                                s
                                             N        ,
                                                                  I
                                                                                                     '
                                                                                                              \
                                                                  -
                                             4                                                                N
                                                                                                              s
                                               l             j          I-                                    s
           ..
                   Tube support                                                                                 7 secondary shell
                       Plate s                  %
                                                        ,       g                g            i ,
                                                l                                I                          o s                                     .
              '
                                             (                                                      "
                                                                                                               4
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                                                                                                                          ATTACHMENT 1
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                   . . . . . . . . . . . . . . . . - . . . . . . . . . . . . . . - . . . . . . . . . . .            _          i  -e
        .
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                                          x - un ZMW CNuMMO                                                                               l
                                                 ATTACHMENT 1
                        AGENDA
                        THI-1
       EfWTURBINEORIVENPUMPMAINSTEAMSAFETYVALVES

I. CONCERN

        MSV22BLIFTSUPONINITIATIONOfEF-P-1
       CONCERN:P0TENTIALSTARVINGOfEF-P-1 TURBINE.

II. EVALUATION

   1. MSV228 LIfI ONLY OCCURS WITH SIMULTANE0US MS-Vl3AlB
       OPENING.
   2. PUMP WILL OPERATE WITH SAFETY VALVE OPEN.
   3. PC-SlMSV-6 RESPONSE T00 SLOW TO PREVENT MSV228 LIFT.

-

                                               ATTACHMENT 1

!

 III.INTERIMACTIONTAKEN
       GUIDANCEPROVIDEDTOOPERATORIfSAfiTYVALVELIFISDURING
       EF-P-1 OPERATION:
       o  OPERATOR INSTRUCTED ON HOW TO RESEAT THE SAFETY VALVE
       o  OPERATOR INSTRUCTED ON WOW TO TAKE EF-P-1 0UT Of
          SERVICE (IfSAFETYCAN'TBERESEATEDANDADEQUATE
          MOTOR DRIVEN FLOW IS AVAILABLD
o OPERATOR INSTRUCTED ON WOW TO OPERATE EF-P-1 WITH

l SAFETYVALVEOPENORGAGGEDCLOSED

l l

I

,

                                                ATTACHMENT 1

I

 IV. CURRENT ACTION PLAN
      1. REVISE INTERIM (CORRECTIVE) ACTION:

l USESINGLEVALVEOPENLOGICF0RSHORTTERM(CYCLE 5) j

         0  JUMPER ACROSS MS-V13B AUT0 START LOGIC T0 KEEP
            HS-V138 CLOSED
         o  MANUALLY OPEN MS-V13B FROM CONTROL ROOM If MS-V13A
FAILSTOPROVIDESuffICIENTSTEAM

l 2. IMPROVE RESPONSE TIME CHARACTERISTICS Of PRESSURE l

CONTR0LERPC-5.
         o  INSTALL NEW PRESSURE CONTROLLER & VOLUME B00 STER

,

         o  TEST FOR ACCEPTABLE PERFORMANCE WITH SIMULTANE0US
            VALVEOPENING.
                                       ATTACHMENT 1

,

                    SUMMARY
 1. MSV22B LIfI OCCURS ONLY WITH SIMULTANE0US MSV13AlB
     OPENING.
 2. O   INTERIMACTIONTOBEREVISEDTOONLYOPENONEMSV13
                                                    -
     o  IMPROVED CONTROLLER TO BE TESTED AS CORRECTIVE
        ACTION
 3. AB0VE ASSURES EF-P-1 OPERABILITY.*.N0 NUCLEAR SAFETY
     CONCERN
                                                                     ATTACHMENT 1
                               MS-V-13A               MS-V13B
                                C                       Q
                       2"            l                          2"
                          a                                   a

[ggM

         , 32"                  k 2       -u,-         k ;                 '12",,[gRQfi

0TSG

         J                      VT                     F7                        3 OTSG
                  fiS-V9A      f1S-V10A    ____    . MS-V10B       I!S-V9B
                                               ' r
             PC-5                            _
                        -
                           7,     e,
                                       (     [       MS-V6
                  MS-V22A                          8"
                                 f1S-V22B
                      -C>
                                                        _
                                                           f1
      Ir    l                           4
                                                        L J              -
                                                                            F10M
                                                                            A!JX  BOILER
    -
                                                  4,,   73             .i
                                                       AS-V4
               -
               EF-U1        EF-P1
               N
                                        Tf;I-1
                                  STEAM SUPPLY TO
                                  EFW PUMP TUPSIf1E
                                                                                      ._
                                           ATTACHMENT 1
                     MAIN STEAM SAFETY VALVES (MSSV'S)
 EVENT
 DATE: 10/21/85
   0   401POWERTRIP
   o   ALL MS$V'S LIFT
   o   NUMBER Of MS$V'S RELIfI
   o   PEAK RECORDED PRESSURE 1050 PSIG
   o   RELIfTS AT APPR0X. 1010 PSIG

-

     .
                                                  ATTACHMENT 1
 -

, I

   .
       EVALUATION

l 1. VALVE SETP0INTS WERE CONflRNED CORRECT.

       2.  VALVE PERFORMANCE

l

           a) ALL VALVES INITIALLY LIFT FRON PRESSURE WAVE AS
               EXPECTED.
           b) BLOWOOWN IS WITHIN ACCEPTABLE B00N05 OIS$V'S 010 NO
               EXCEED 101 BLOW 00WN)

i c) PROLONGE0 INITIAL LIfI COULD RESULT IN NSSV SEIP0lNT

               ORIfI(ASMUCHAS31)
           d) CONSISTENT WIIW OBSERVATIONS AI OTHER PLANTS.

1 i

                                         ATTACHMENT 1
 3. ANALYSIS SHOWS A SYSTEM PRESSURE SPIKE RELATED T0 IURBINE

( STOP VALVE CLOSURE IN EXCESS Of HIGHEST MS$V SET P0 INT. !

 4. SAFETYVALVEPERFORMANCEMAINIAINEDPLANTWITHINDESIGN
    ENVELOPEDURINGTRIP.
 5. INADVERTANT 75% POWER TRIP SHOWE0 REPEATABILITY.

l < l L

                                                              -__

(,- .

   ,
                                                 ATTACHMENT 1
                                                                  ,

'

     CONCLUSION

l ,

     l.  THI-l MSSV SEIP0lNIS ARE SET CORRECILY.

l l 2. IMI-l MSSVS RESPONDED WITHIN EXPECTED TOLERANCES DURING 1

         THEPLANTTRIP.

l '

     3.  THI-l CURRENT SEIP0INTS ARE ADEQUATE FCR CONTINUED S
         PLANTOPERATIONATALLPOWERLEVELS.

l

     4.  GPUN WILL CONTINUE TO INVESTIGATE MEANS TO IMPROVE TH

l ALREADYACCEPTABLESITUATION. l l l , < }}