ML20137X379
| ML20137X379 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 11/26/1985 |
| From: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8512100501 | |
| Download: ML20137X379 (11) | |
Text
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N0y 2 01985 59640)
L MEMORANDUM FOR: Thomas E. Murley, Regional Administrator j THRU: Richard W. Starostecki, Director Di~ vision of Reactor Projects FROM: William F. Kane, Director i
! TMI-1 Restart Staff l L
SUBJECT:
TMI-1 RESTART: i,RC HOLD POINT FOR ESCALATION T0 75%
I~ p0WER
[ The purpose of this memorandum is to summarize the status of the NRC inspection program for TMI-1 and to document my recommendation of November 22, 1985, that the licensee should be released to proceed beyond the. fourth NRC hold point. Enclosure 1 is a summary of our assessment of the plant status and equipment operability, personnel knowledge and performance, testing program status, applicable license / restart conditions, allegations, and enforcement actions. Enclosure 2 provides the current status of license / restart conditions applicable to this hold point.
During the period since the last hold point, the plant has operated at steady-state 48% power conditions with only minor testing activities. As such, the operating environment was very similar to that of normal' plant operation as compared to earlier periods during which testing predominated. Due to the good performance in the licensee's operations area in prior periods, we focused more of our inspection activities during this period on other areas; e.g., maintenance and surveillance activities. Our coverage during this period was for sixteen hours each day and covered all or part of the licensee's three operating shifts.
The number of negative observations by our inspectors increased relative to prior periods. Most'of these observations related to the poor performance by some personnel in the implementation of procedures. I personally discussed this performance with the licensee and a corrective action plan has been undertaken by the licensee which if properly implemented should correct the problem. None of the examples of poor performance has resulted in adverse safety consequences.
The licensee's management has continued to approach the restart program with caution and has proceeded at a deliberate pace to assure that it is carried out in a safe manner. The open items are relatively few in number, all applicable conditions have been satisfied, and there are no allegations or enforcement actions that should preclude authorization to proceed. There were no events during the period that required NRC notification.
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Thomas E. Murley 2 Therefore, I recommend that you authorize the licensee to proceed with the test program up to the next hold point, which is at the completion of testing and training at the 75*4 power level. The licensee estimates that this will occur betweeri Christmas and New Year's day.
(J William F. Kane, Director TMI-1 Restart Staff
Enclosures:
As Stated cc w/ enclosures:
H. Denton, NRR N. Grace, Region II J. Keppler, Region III R. Martin, Region IV J. Martin Region V V. Stello, EDO J. Taylor, IE-W. Travers, TMIPO, NRR
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- Thomas E. Murley 3 j;-
bcc w/ enclosures:
' Region I Docket Room (w/ concurrences)
Public Document Room Local Public Docume'nt Room W If3 R t rostecki T
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a ENCLOSURE 1 * .
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ASSES $MENTOFLICENSEkREADIhESS TO PROCEED'BEYOND 48% POWER LEVEL
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[. w 1. Inspection Coverage ,
TheTMI-1RestartStaffdiscoNinuedits24-hourshiftcoverageat
-o 6:00 p.m., October 24,1985. , 'Thist coverage was reduced to sixteen A V hours a day consistent with the reduced level of testing activity throughout the current e riod. Personnel from Regions I, II, and-i i
IV,theNRCTraining.Cen5er,'andNRCcontractorpersonnelfrom ,
Battelle Pacific Northwest %aboratories, and EG&G Idaho, Inc, manned the shifts.
- Inspection plans continue to be developed for shift operational assessment, resident / region-based operational assessment, test witnessing and data evaluation, and supplemental inspections by region-b.ts ed inspectors in specialty areas such as radiation protection or licensed operator requalification training.
. These inspections have provided us with an excellent insight into the licensee's overall performance. We completed the fifty-first consecutive day of our expanded shift co erage on November 23, 1985.
ThescopeanddurationlofthisNRCinspec(tioncoverageare unpreced g ted for an opepting plant.
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- 2. Testing Program There were very few tests planned during operation at the 48%
plateau;.however, progress continued in the proper implementation of the ' tests listed below for this plateau. These included the following.
(1) TP 800-5,'" Unit Load Steady State Test",.- A portion of this test was repeated at 15% power duringsrestart after the 40%
trip to reverify the correlation between Tave and once-through steam generator (OTSG) water level at this power level, i (2) TP 849-1, "ICS Tuning" - Power level was changed from 48% to 40% and back to 48% to determine the relationship of rate of charge to the unit load demand. -
(3) TP 800-1, " Controlling Procedure for Power Escalation" -
Recorded data to determine adequacy of secondary side plant efficiency.
9.s (4) SP 311/10 - Comparison of Bailey and Mod-Comp computer data readings. g (5) OP 1109-1'4, " Loose Parts Vibration Monitoring Data" - Continued to establish base line data atgach, test power level.
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r 2 Enclosure 1 On November 15, 1985, the licensee conducted a meeting to evaluate all test results to date. This meeting concluded that all test data were satisfactory to permit continuation of power escalation testing above 48%
power. We reviewed the results of that meeting and other test data and we independently concurred with that conclusion.
Overall, our review indicates that the test procedures were properly implemented and data collection was in accordance with licensee procedures and regulatory requirements.
- 3. Plant Status and Equipment Operability As of 2:00 a.m. on Saturday, November 23, 1985, the plant was operating at steady-state 48% power conditions with the reactor coolant system at 530 F and pressure at 2155 psig. The licensee completed its evaluation of test data and equipment performance and was awaiting release from the NRC hold point.
No major safety related equipment is out of service. Equipment is periodically taken out of service in accordance with the action statements of technical specifications to perform surveillance and preventive or corrective maintenance. Some items of interest that occurred during the period with respect to safety-related equipment or had the potential to affect safety-related equipment are summarized below (details are described in the weekly status report and applicable inspection reports for this period).
On November 4, 1985, one of the two emergency diesel generators was removed from service, as permitted by the plant's technical specifications, for annual preventive maintenance and inspections. The diesel generator was returned to service on November 8, 1985, and a 24-hour operational test with the diesel generator loaded to 3000 kilowatts was completed satis-factorily as well as other required post-maintenance surveillance testing.
After that diesel generator was officially declared operable, the other emergency diesel generator was removed from service on November 11, 1985, for similar annual maintenance and testing. Work on the second diesel generator was completed and a 24-hour endurance test was completed'on -
November 16, 1985, and the diesel generator was declared operable.
On November 5, 1985, the licensee removed one of the two letdown coolers from service because of an indicated leakage at the rate of 1.3 liters /
day. The letdown cooler is part of the makeup and purification system and is used to lower the temperature of the reactor coolant such that it can be processed and then returned to the reactor coolant system. Leakage of the reactor coolant was into the intermediate closed cycle cooling water system, a non-safety system. The leakage was first detected on October 24, 1985, by radioactive noble gas sampling and trended on a daily basis.
Although the cooler is still considered to be operable by the licensee, it is not in service. The licensee has a spare letdown cooler available on site if needed.
I i > 3. Enclosure 1 t l fk
'We continue to conclude on the basis of.our inspection findings that there are no conditions with respect tp equipment operability that L would adversely affect safe operation of the facility. Safety-
' related areas remain acceptable with respect to housekeeping and fire' protection-measures.
- 4. PersonEel Per'formance q
'Overall, licensed operators continued to demonstrate an acceptable level of knowledge,of plant. design and updated plant status. Our, operator examiners conducted detailed interviews with selected licensed personnel to-assess the effectiveness of training recently received during the power escalation program, such as in'the area of natural circulation and ICS maneuvering. Although our sample size will be increased, we found that c
the operators we interviewed have a detailed knowledge of this information.
However, we also found that <their restart qualification program was really mislabelled, since effective performance-oriented training was provided by the licensee's training department prior to restart and by actual plant experience during the restart program, Ironically, the persistent drain line problems noted in the last hold point memorandum were a valuable training aid in turbine generator operations and ICS maneuvering, especially in switching to manual control. We were able to conclude that the licensee's operators are gettin'g valuable training experience from the.
. extended power escalation program.
Licensed operators were involved in some performance problems as noted below; however, when activities outside the control room challenged the
- plant, the operators under the leadership of the plant operations manager responded well to avoid plant trips or challenges to safety-related
! systems.
t During this period we had the first opportunity to view personnel perfor- ,
mance (including management) during steady-state conditions in which the ,
r focus of activities shifted from a test orientation to an operations orientation including preventive / corrective maintenance and surveillance.
The following eve.ts had the potential to cause either a plant trip or challenge to safety related systems and operators: high level in the secondary plant moisture separator potentially causing a turbine trip;
-moisture separator drain system steam leak potentially causing a-loss of j feedwater; and a leak in a makeup pump potentially. causing a pressurizer i level transient. Procedures were used.to control these evolutions but l better planning and/or interfacing with operations and radiological <
l controls could have prevented the events. Control room operators were :
alert and responsive to the symptoms in the control room to avoid safety '
system challenges. To a lesser extent, other events also created the potential for a plant trip or challenge to safety-related systems and operators. These included a main turbine generator electro-hydraulic '
control transient due to an electrician plugging instrumentation into ICS panels; personnel standing on equipment, a persistent problem which to date has not resulted in an adverse condition; and an inadvertent increase I
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l 4 Enclosure 1 i in reactor power due to an I&C technician hitting the unit load demand controls. These can be attributed to a lack of attention to detail on the part of plant personnel; however, there were no adverse safety con-sequences.
There also was a problem in failure to establish procedures in two areas. One was the resolution of the safety-rods-out interlock problem which involved control rod drive manipulations to override an interlock without procedures. Further, the pressurizer code safety valve tailpipe (flow) differential indicator was inadvertently taken out of service because of an operator's attempt to take a gas sample on the instrument leg without a procedure.
There were other examples of minor procedure nonadherences which collectively raised a concern on an apparent lack of attention to detail. Many of these could have been avoided had personnel properly changed procedures. This is contrary to the licensee's administrative controls and to a certain extent uncharacteristic of the licensee's overall policy on procedure review, approval, and implementation. The problem above also apparently relates to a ,
misperception on the part of some personnel to a previous management position to avoid excessive use of temporary changes to procedures.
In most cases, however, procedures are used and properly implemented.
Self review appears to be a strength of the licensee's organization with numerous incident reports generated as a result of the above problems. Those reports adequately developed lessons learned and corrective actions.
As expected, personnel errors occurred in addition to the procedure implementation errors noted above. Examples included inappropriate deenergization of an electrical bus and inadvertent deenergization of a reactor building fan. Licensee response actions and corrective measures were appropriate and in one situation, where personnel cooperation was a problem, disciplinary action was taken.
- 5. Restart Conditions During this period we reviewed and certified compliance with two additional restart conditions beyond the last hold point.
Enclosure 2 provides the updated inspection status for applicable ,
steam generator and restart hearing related conditions.
- 6. Allegations There are no open allegations in Region I for TMI-1.
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. 5 Enclosure 1
- 7. Pending Enforcement Issues Forthcoming inspection report IR 85-25 will describe a violation of low severity level involving the posting of uncontrolled and unapproved drawing and procedural notes inside control room cabinets. The examples of failure to properly establish procedures, failure to follow or. properly revise established procedures and failure of the Independent Onsite Safety Review Group (IOSRG) to comply with technical specifications independent review requirq,ents are being considered for appropriate enforcement action (NRC '
Inspections 85-26 and 85-27).
- 8. Conclusions The testing program for this period is complete and the plant is physically ready for operation above 40% power. Recent equipment problems were corrected and appropriate operational testing was conducted. A procedure implementation problem was uncovered with the performance of some personnel in the implementation of procedures. The licensee has committed to a corrective action program which if implemented properly should correct this problem.
This area will be closely followed by the TMI-1 Restart Staff during operation at the 75% plateau to determine if the licensee's program is effective.
The licensee continues to be generally attentive and aggressive in resolving day-to-day problems, in particular those identified by the TMI-1 Restart Staff. The licensee's actions continue to be oriented toward nuclear safety.
Although there has been some slip in the licensee's overall performance during the period of steady-state operation at 48%
power, the overall level of performance remains acceptable.
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5 Enclosure 2 STATUS OF APPLICABLE LICENSE / RESTART CONDITIONS FOR CURRENT HOLD POINT (Steam Generator Repair License Conditions)
No. Short Description Inspection _ Status / History 2C(5) Implement a secondary IR-84-07 water chemistry monitoring IR-85-17 program to inhibit steam IR-85-19 generator tube degradation Complies 2C(8) Prior to criticality, submit IR-84-07 (1) to NRC results of OTSG hot IR-85-16 test program and management IR-85-18 review. Complies (2) Confirm baseline leakage and IR-85-16 shutdown if leakage exceeds IR-85-18 0.1 cpm above baseline (repair IR-85-19 and retest). Complies (5) Quality report on long term Not applicable, corrosion level tests. reports being sent to NRR (TMI-1 Restart Hearing Conditions) 1 (a) Restriction of work in Fuel IR-84-33 l Handling Building (FHB) at When required, TMI-1 during TMI-2 fuel inspection will be L handling in FHB. scheduled l
l (b) Separate solid waste handling IR-81-34, IR-82-03 facilities. IR-82-21, IR-84-33 (OI 84-33-01)
IR-85-17 Complies (c) ESF filtration system for IR-84-33, 85-20 t TMI-1 FHB (prior to TMI-1 When required, fuel movements), inspection will be scheduled (d) Liquid radwaste system IR-82-21 isolation between TMI-1 IR-83-01 and 2. IR-84-33 IR-85-19 Complies
4 2 Enclosure 2 No. Short Description Inspection _ Status / History (e)-(k) Unique shift manning IR-85-19 requirements. '
Complies (1) Management system for IR-80-19, IR-81-33, feedback to operators. IR-82-09, IR-82-16 IR-82-18, IR-83-01 IR-24-33 Complies (m) Restriction on former IR-82-19 Startup and Test Director. IR-84-33 .
Complies (n) Preserve records for Not Applicable investigation of VV false (Office of Investi-certification gations)
(o) Operators to use instruments IR-85-19 closest to saturation for Complies HPI throttling until the Backup Instrument Readout (BIRO) system is safety grade.
(p) Until EFW is safety grade IR-83-32 dispatch auxiliary operator IR-84-33 to EF-V 30A/B. IR-85-19 Complies (q) Reactor to be subcritical IR-83-32 on hot standby with IR-84-33 pressurizer heaters on IR-85-19 emergency bus. Complies (r) Modify Emergency Plan for IR-84-33 changing plant instrument IR-85-17 capabiTities. Complies (s) Restriction on TMI-2 IR-85-19 operating crew from Complies .y operating TMI-1.
(t) Nuclear Safety and Compliance IR-84-31 Committee (NSCC) to be retained. IR-85-25 (issuance pending)
Complies (u) Restriction on individuals IR-85-19 who replied to accident Complies violations.
3 Enclosure 2 No. Short Description Inspection _ Status / History 2 (a) Before 5% power implement IR-85-22 low power test program Complies and training on natural circulation.
(b) Before going above 48% IR-85-25 power, initiate emergency (issuance pend'ng) feedwater on loss of main Complies feedwater.
(c) Before 5% power, functional IR-85-22 ~'
test 2-hour backup air Complies supply to EFW 5 (a) October of each year IR-85-24 submit progress report on Complies installation of exact replica simulator (b) Until replica simulator IR-84-19 is available, provide one IR-85-25 week training on Basic (issuance pending)
Principles Simulator. Complies (c) Implement a leakage IR-83-14 program for systems IR-84-23 outside containment. IR-85-18 Complies