ML20141D909
| ML20141D909 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/24/1986 |
| From: | Blough A, Conte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20141D894 | List: |
| References | |
| 50-289-86-01, 50-289-86-1, NUDOCS 8604080312 | |
| Download: ML20141D909 (41) | |
See also: IR 05000289/1986001
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-289/86-01
Docket No.
50-289
License ho.
Priority --
Category C
Licensee:
GPU Nuclear Corporation
Post Office Box 480
Middletown, Pennsylvania 17057
Facility At:
Three Mile Island Nuclear Station, Unit 1
Inspection At:
Middletown, Pennsylvania
Inspection Conducted:
January 10, 1986 - February 7, 1986
Inspectors:
W. Baunack, Project Engineer, Region I
R. Conte, Senior Resident Inspector (TMI-1)
J. Dunlap, Physical Security Inspector, Region I
A. Krasopoulos, Lead Reactor Engineer, Region I
W. Madden, Security Inspector, Region I
C. Tavares, Physical Security Inspector, Region I
R. Urban, Reactor Engineer, Region I
A. Weadock, Radiation Specialist, Region I
F. Young, Resident Inspector (TMI-1), Region I
3d d
^
Reporting Inspector:h [R. Conte, Seni# Resident Inspector (TMI-1)
Date
[A.' Blojufh, Chief
d
t/ T,
Aporoved By:
Da'te
Reactor Projects Section No. lA
Division of Reactor Projects
Inspection Summary:
Resident and region-based NRC staff conducted routine safety inspections (388
hours) of power operation, focusing on plant and personnel performance.
Specifically, items reviewed in detail in the operations area were: control
rod drive position indication switches; decay heat relief valve actuation;
makeup demineralizer hot spot flush; waste gas routine release; and heatup/
startup activities.
Special focus occurred on licensee event actions for a
reactor protection system breaker shunt trip malfunction and for a partial
loss of ICS/NNI power. Other review items included:
independent technical
and safety review; radiation protection program implementation; security plan
and implementation procedures; fire protection plan and implementation proce-
dures; and licensee action on previous inspection findings.
8604080312 860402
ADOCK 05000289
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Inspection Results:
Licensee personnel exhibited good control of operations and of shutdown and
startup activities. Operators were responsive to off normal events and
properly implemented facility procedures.
Licensee management continued an
aggressive attitude on conducting corrective maintenance and in implementing
an ambitious preventive maintenance program. However, some recent events
revealed poor irterface between the maintenance and fire protection personnel.
Enhanced job planning could have improved licensee activities on the makeup
system demineralizer hot spot flush.
The fire protection program was adequate, except as noted below, and personnel
properly implemented respective procedures.
The inspection identified an
apparent violation on the adequacy of fire brigade response actions (det:lls,
paragraph 7.6.3.1).
The inspection identified a number of other unresolved
issues for which more information is needed.
The security program was adequate and personnel properly adhered to respective
implementing procedures.
The licensee properly implemented the independent technical and safety review
program in accordance with Technical Specifications. The program required
reports on such reviews could be enhanced with more consistent methodology
among divisions. The TS program elements were met despite the diversity and
complexity of the system. This area will continue to be reviewed by NRC's
Region I with respect to review adequecy.
The licensee appears to be properly planning the eddy current outage f:om a
modification and health physics viewpoint.
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DETAIL}
1.
Introduction and Overview
1.1 NRC Staff Actitities
The overall purpose of this inspection was to assess licensee
actiaties for the power operation mode as they related to reactor
sdfety, worker radiation protection, and security / safeguards
measures. Within each area, the inspectors documented the specific
purpose of the area under review, and the scope of inspection
.'
activities and findings, along with appropriate conclusions. The
inspectors made this assessment by reviewing information on a samp-
ling basis through actual observation of licensee activities, inter-
views with licensee personnel, measurement of radiation levels, or
independent calculation and review of listed applicable documents.
.
1.2 Licensee Activities
The licensee operated the facility at full power during this inspec-
,
tion, except for one week. At the beginning of this period, the
licensee completed residual startup testing for the 100% power
.
(startup testing) plateau.
This test was Refueling Procedure (RP)
1550-09, Unit Acceptance Tests. The data were reviewed by the NRC
staff and the review was documented in NRC Inspection Report No.
50-289/85-30.
Between January 27 and February 3,1986, the licensee placed the
plant in cold shutdown in order to break vacuum in the main condens"
,
er to repair leaking pipe expansion bellows on the eighth stage
extraction steam lines. The licensee entered the "C" condenser
through an opening cut in the side of the main condenser.
The
licensee found both eighth stage expansion bellows to be signifi-
cantly deteriorated; both were replaced.
The licensee performed a
,
search of the main condenser and extraction steam lines to locate
and remove pieces of the damaged expansion bellows. A visual
inspection of the remaining tenth and twelfth stage expansion
bellows in the "C" condenser was conducted and no apparent deterio-
,
ration was found.
Based on what was found in the "C" condenser, the licensee decided
t
to examine the other eighth, tenth, and twelfth stage expansion
bellows in the "A" and "B" condensers. A visual inspection found
cracking on all four of the eighth stage expansion bellows; they
were replaced.
No apparent deterioration was found on the tenth and
twelfth stage expansion bellows.
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Repair work was completed on February 2.
The damaged expansion
bellcws were sent off site for metallurgical examination to deter-
mine the cause of the failure.
Following restart of the plant, an
approximate 35 MW(e) increase in power was noted.
At the end of the inspection period, the plant was at full' power at
normal operating pressure (2155 psig) and temperature (579 F).
2.
Plant Operations
2.1 Scope of Review
The TMI-1 Resident Office inspectors periodically inspected the
facility to determine the licensee's compliance with the general
operating requirements of Section 6 of the Technical Specifications
(TS) in the following areas:
review of selected plant parameters for abnormal trends
--
plant status f roni a maintenance / modification viewpoint, includ-
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ing plant housekeeping and fire protection measures
' control of cngoing and special evolutions, including control
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rcam personnel awareness of these evolutions
cor. trol .of documents including logleeping practices
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implementation of radiological controls
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implementation of the security plan, including access control,
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boundary integrity, and badging practices
The inspectors focused their attention en the areas listed below.
cor.trel roota operations during regular and backshif t hours,
--
including frequent obseryation of activitie's in progress, and
periodic reviews cf selected sections of the shift foreman's
log and centrol rcom operator's log and other control roem
claily logs
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followup items on activities that could affect plant safety or
impact plant operations
areas outside the control room
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selected licensee planning teetings
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Because of additional resident inspector coverage at this facility,
special attention was given to those areas listed in Attachment I
to the report. As a result of this review, the inspectors reviewed
specific events in more detail as described in the sections that
follow.
2.2 Findings
2.2.1
General
Licensee management continued their presence and involve-
ment in daily activities. The quality assurance depart-
ment sustained their presence and detailed involvement in
licensee activities.
Positive control and adequate
preparations were demonstrated during the week-long forced
outage for steam line expansion bellows replacement. The
plant shutdown and subsequent startup went smoothly
without significant problems.
2.2.2
Malfunction of CRD Reed Switches
Two methods of control rod position indication are used --
relative and absolute.
Relative position indication
monitors input pulses to the control rod drive (CRD) motor
while absolute position indication monitors the position
of the control rod through the use of reed switches.
There are 45 equally spaced reed switches mounted in a
fiberglass housing that is strapped to the motor tube of
the control rod drive mechanism (CRDM).
These reed
switches are closed by a magnet attached to the torque
taker; as the control rod moves in and out of the core,
the magnet passes by the reed switches. A reed switch is
held closed whenever the magnet is within 1.5 inches above
or below it.
As the reed switch closes, electrical
contact is made varying the resistance of the circuit,
which is then translated to position indication. Once the
magnet passes by, the reed switch opens and electrical
contact is broken.
Occasionally, the licensee experiences problems with these
reed switches.
This is indicated by a " fault" light on
the position indication panel and an asymmetric rod alarm
when the magnet on the torque taker passes a defective
reed switch.
The problem occurs when a film forms on the
surface of the reed switch contacts, preventing the switch
from closing electrically. The film apparently forms on
the reed switches from impurities that leach out from the
glass tubes.
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In the past, the licensee would remove defective reed
switches and send them to the vendor (Diamond Power
Corporation) for repair. The vendor would apply 5 volts at
100 milli-amps to the defective reed switch to " burn-off"
.
the film. The success rate was approximately 75%. The
licensee decided to implement this simple method on site
to repair the defective reed switches.
The inspector reviewed corrective maintenance procedure
1430-CRD-19, "CR0 PI Tube Troubleshooting, Repair or
,
Replacement," Revision 3, dated December 11, 1985, Attach-
ment 2, " Repair of a Defective Position Indicator Reed
Switch." The inspector also reviewed the machinery
history file for the CRD system to review job tickets
associated with this procedure.
The inspector found no discrepancies in the procedure.
If
the " burn-off" method fails to solve the problem, the
procedure states tha+ the reed switch will probably need
to be replaced. The ,spector determined the success rate
to be approximately 7C. with respect to the onsite refur-
bishment.
The inspector had no further questions in this
area.
2.2.3
Decay Heat Removal (DHR) System Leakage
During a reactor coolant system (RCS) cooldown on January
29, 1986, when the decay heat removal system was placed
into operation, a relief valve (DH-V57B) lifted spilling
water on the auxiliary building floor and into the floor
drain system. (The relief valve is mounted on the DHR
pump suction line between the BWST suction valve and a
downstream check valve (DH-V148)). The lifting of the
relief valve was attributed to leakage past the check
'
valve. This leakage caused a buildup of pressure between
the check valve and the closed BWST suction valve.
Technical Specification (TS) 4.5.4 states that the maximum
allowable leakage from the DHR system components as
<
measured during refueling tests shall not exceed 6 gallons
per hour.
Since this leakage via the lifted relief valve
during system operation was in excess of 6 gallons per
hour, the inspector requested the Plant Review Group (PRG)
to review this occurrence to verify compliance with the TS
requirement.
The PRG met to review this information in relation to TS 4.5.4 on February 4, 1986.
The PRG concluded the piping
which contains the leaking check valve is required by TS
to be tested at no less than 55 psig. The relief valve
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setpoint is much greater than 55 psig (150 psig) and,
therefore, would not and did not lift under conditions
where the R.CS pressure was less than the relief valve
setpoint. The PRG also concluded that under accident
conditions at which RCS high activities might be experi-
enced, the pressure in the OHR suction side piping would
be low.
For these reasons, the PRG concluded the TS was
being met.
Additionally, the PRG reviewed the situation from an
operational point of view and concluded that in order to
avoid radioactive spills and generation of radwaste,
lifting of the relief valve should be avoided. Accord-
ingly, operations will review the decay heat removal
procedure and will provide appropriate cautions against
establishing decay heat removal at RCS pressures that
could challenge the relief vzlves when RCS activity could
cause a significant release.
It was also noted that the leaking check valves (only
DH-V14B leaked during this event; however, OH-V14A is also
known to be leaking) are scheduled for repairs during the
next refueling outage.
The NRC will verify the repair of
these valves at that time. This item is unresolved
(289/86-01-01).
The inspector agreed that, in the interim, until the
valves are repaired during the next refueling outage, the
procedural controls recommended by the PRG were adequate.
2.2.4
Makeup Demineralizer Hot Spot Flush
On January 10, 1986, the licensee decided to flush a hot
spot out of the resin fill line to the makeup and purifi-
cation mixed bed demineralizer (MU-K1A) for ALARA consid-
erations.
The hot spot was located in a Icw section of
piping between CA-V129A and the demineralizer; the dose
rate of the hot spot was 175 R/hr. The valv'e and assoc-
iated piping is located in " mini-valvo alley" on the
305' elevation of the auxiliary building.
Licensee representatives believed the hot spot was com-
posed of contaminated resin that apparently lifted-off the
demineralizer bed and cettled out in a low section of
piping next to CA-V129A. An ALARA review was conducted on
January 8,1986 to determine RWP requirements and the
manner in which the flush would be carried out. Opera-
tions personnel were to line up and vent the demineralizer
to the spent resin storage tank. By using reclaimed water
from the chemical addition room, the flushing water would
pass through the piping, CA-V-129A, demineralizer bed and
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into the spent resin storage tank. The objective was to
move the contaminated resin beads from the piping into the
demineralizer bed.
The licensee depressurized and drained MU-KIA slightly to
allow room for flushing water. Using applicable sections
of OP 1104-54, " Makeup and Purification Demineralizer
Resin Replacement," a'pproximately 50-100 gallons of' water
were used for the flush.
The flush appeared to be suc-
~
cessful because the hot spot dose rate was reduced to 500
mR/hr. To return the system to operation, it needed to be
vented and filled with water. During the venting opera-
tien, contaminated resin beads were carried into vent
piping outside of the cubicle along an adjacent pas.sageway.
Because of the r.ew hot spot, the passageway had to be
posted as a radiation area.
During the ALARA review, licensee representatives thought
that there was a resin trap at the exit of the demineral-
12er tank prior to entering the vent header. Based on
this assumption, licensee representatives did not think
that contaminated resin could be swept into the vent
header. A subsequent review of the system drawings by the
licensee revealed that there was no resin trap installed.
A licensee representative stated that almost every resin
tank similar to this one has a resin trap at thG vent
exit; this was the basis for their assumption.
Licensee representatives used poor judgement in assuming
that a resin trap was present at the exit of the
demineralizer tank. The inspector noted that OP 1104-54
contained a caution statement that resin could be observed
in the vent sight glass during the venting operation.
This should have keyed licensee representatives to
the fact that there was no resin trap present. Normally,
small amounts of resin observed in the sight glass is not
a major probles; because it is clean resin. Other aspects
of this flushing operation were carried out well and in
accordance with procedures.
The inspector also reviewed licensee surveys and posting
of the radiation area to determine if they were in accor-
dance with procedural requirements. Current surveys of
mini-valve alley and the adjacent hallway refletting the
new radiological conditions were available at the control
point and the technician performing the survejs appeared
knowledgeable in general survey practices and techniques.
Shielding and posting efforts in the hallway outside
mini-valve alley were found to be adequate. The inspector
had no further questions in this area.
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By mid-February 1986, radiation dose rates inside the vent
header had decayed significantly; the highest reading was
100 mR/hr contact. The inspector agreed with the
licensee *s conclusion that the vent header would not need
to be flushed as long as dose rates from the vent header
continued to decrease and ' remained low.
,
The inspector expressed his concern to licensee management
that future hot spot flushing operations of contaminated
resin could be enhanced with better iob planning. The
s
licensee representatives acknowledged the inspector's
concern.
The inspector had no further questions in this
area.
2.2.5
Waste Gas Release
d
During release of the
B" waste gat decay tank to the vent
stack on Saturday, January 18, 1986, tne discharge caused
the vent stack radiation monitor to reach the icwcr of two
clarn setpoints.
In response to this alarm, the release
was stopped and c sample was taken tc determine activity
levels in the tank. This sample confirmed the original
calculaticns, and the release, which totaled about 2.8
curies, was completed.
Later that day, approximately five hours after the release
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was completed, one of the offsite radjation monitoring
stations about one-half mile west of the plant alarmec
me.mentarily. The two events were reviewed by the licensee
and were determined to be unrelated.
The offsite
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vadiation monitor alarm was concluded to be a spurious
alarm.
This particylar station transmits its data via
radio signal. No other stations alarmed.
T.he inspector reviewed the licensee's actions to ensure
thet the 6 volution had been conducted in accordance with
applicable station procedures and that the release did not
exceed any discharge limits. The inspector independently
reviewed the antlytical results of the grab samples taken on ths
waste gas tanks to determine the amount of activity baing
discharged and reviewed the meteorological conditions at
the time of the release and the subsequent five hours.
The neteorological dat.a demonstrated that the discharges
from the plant would have been swept f n the direction of
the detector in question.
However, at th9 time of the'
alarm, the licensee had termi.nated the release several
hours prior tc the alarm from tha offsite detectof. Due
to the amount of activity discharged and the dispersion of
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this material that would have occurred, the inspector
concurred with the licensee's characterization of the
event.
2.2.6
Reactor Plant Heatup and Startup
_
On Janua y 27, 1986, the licensee commenced a shutdown of
TMI-1 for a forced outage to repair a leating expansion
bellows on a feed heater extraction steam line (see
paragraph 1.2).
On February 2,1986, the licensee completed repair work
and commenced a plant startup. The plant was returned to
full power by February 6, 1986.
Following restart of the
plant, an approximate 35 MWe increase in power was noted.
The inspector was,present and witnessed major portions of
the forced shutdown and subsequent startup.
In addition,
visual inspection of the ruptured bellows and other
maintenance related work was conducted. The inspector
noted work was being performed in accordance with station
procedures and personnel performing the work were knowledge-
able about their tasks. Discussions with control room
operators demonstrated that they were . aware of plant
status. Porticns of the startup witnessed were perfo.rmed
in accordance with applicable procedures. Actual middle
management presence in the control room and in the plant
was noted on a continuous basis during plant shutdown and
startup.
Presence of management appeared to aid in allow-
ing the licensee to complete the repairs in a timely and
,
safe manner.
2.3 Cor.c.l usi on
Operators continued to conduct themselves in a competent manner and
their performance-orf ented actions reflected a strong training
program. Licensee management and the quality assurance department
continued their presence and involvement in daily activities.
Final
preparation for forced outage work was conducted at a fast pace, but
management control ensured ao adverse regulatcry or safety condi-
tions resulted.
In general, operators were responsive to daily
plant problems as they arose. Overall, procedures were properly
implemented. Radiological control practices were gued.
.
As eculpment problems became evident, appropriate corrective mainte-
'
nance was planned, scheduled, and implemented as evidenced by the reed
switch problem. The licensee continued to implement an aggressive
preventive maintenance program. One job, the flush of the makeup
demineralizer hot spot, could have been better theyght out prior to
implementation. Overall, personnel acted cautiously when abnormal
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situations arese, such as during the identification of a hot spot
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immediately after flushing.
Personnel awareness and caution were
also exhibited when the lifted DH relief valve was seated in order
to minimize the spread of contamination and minimize liquid radwaste
generation.
3.
Event Followup
~
3.1 Failure of RPS Shunt Trip Breaker
3.1.1
Event Chronology
s
At 2:26 p.m. on Jarciary 14, 1986, during monthly Reactor
ProtectionSystemNRPS)surveillancetesting,oneofthe
two a.c. reactor trip breakers (CB-11) failed to open when
its shunt trip feature was tested. The plant was at
normal temperature and pressure at 100% power. Just
prior to the failure, the breaker's undervoltage (UV) trip
feature had been tested successfully.
Subsequent to the init'ial failure of the breaker to open,
the test switch was placed in the shunt trip position two
or three additional times; the breaker still failed to
open.
s
In accordance with Technical Specifications (TS 3.5.1.6),
the licensee tested the other a.c. breaker, four d.c.
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breakers, and tagged open CB-11. A faulty circuit board
i
was replaced with a unit from stock and CB-11 subsequently
passed the surveillance test at 7:00 p.m. that day.
3.1.2
Event Review
The inspector reviewed the event to determine the follow-
ing information:
'
--
details regarding the cause of the event and event
chronology;
--
consistency of licensee actions with license require-
ments, approved procedures, and the nature of the
event; and,
proposed licensee actions'to correct the cause of the
--
event.
.s
The inspector's review of the breaker malfunction included
discussions with cognizant licensee personnel and review
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A
of the following documents:
system electrical drawings;
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surveillance procedure (SP) 1303-4.1, " Reactor
Protection System;"
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temporary procedure (TP) 400/0.1, "ITE-27H Solid
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State Relays Calibration CRDM Circuit Breaker Modifi-
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cation," Revision 0, MXT 5.3.5.1.2.
The inspector also examined the failed ITE undervoltage
relay to assess the licensee's conclusions.
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3.1.3
Licensee Findings
'
The licensee began troubleshooting the ITE/ Brown Boveri
undervoltage relay and discovered that K1 (output relay)
g
was not closing when the undervoltage relay was
a
de energized.
Subsequent troubleshcoting revealed that a
48/125 VDC control voltage jumper on the undervoltage
relay was plugged in the 48 VDC position instead of the
125 VDC position.
Therefore, the undervoltage relay was
set to operate at an input voltage of 48 VDC instead of
the applied input voltage of 125 VDC. An overheating
M
condition was created and was evidenced by yellow discol-
oration and deformation of the originally clear plastic
cover for Kl. Overheating was also indicated on one other
resistor.
The licensee determined the cause of the failure to be
.
improper voltage set-up of the ITE undervoltage relay due
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to an incorrectly located control voltage jumper.
The
faulty undervoltage relay was calibrated and checked for
proper control voltage jumper placement. The shunt trip
portion of RPS breaker CB-11 was retested and was found to
be operable.
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As a preventive measure, the licensee inspected the
undervoltage relay for RPS breaker CB-10 and two other
a
undervoltage relays in the plant and determined that the
3
control voltage jumpers were in the proper location. The
_
licensee also functionally tested the shunt trip portion
of CB-10 and verified it to be operable.
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The licensee decided that the event was not reportable;
'
but when requested by the inspector, the licensee agreed
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to submit a special report.
3.1.4
NRC Staff Findings
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The licensee's initial actions in response to this event
were timely and consistent with license requirements,
approved procedures and the nature of the event.
The
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inspector agreed with the licensee's conclusion that an
incorrectly located control voltage jumper caused the
output relay (K1) to overheat and fail.
The licensee bought the undervoltage relays from ITE/ Brown
Boveri but had their subsidiary -- Metropolitan Edison,
Lebanon Relay Department -- calibrate then using TP
400/0.1. A QC inspector from the licensee's QC department
witnessed testing of three pridervoltage relays and re-
viewed the data associated with four other undervoltage
relays. Therefore, QC receipt inspection was not per-
formed.
The inspector's review determined that TP 400/0.1 did not
adequately check for the proper location of the control
voltage jumper nor require an independent verification of
that jumper.
From discussions with licensee personnel and
review of calibration data, the inspector determined that
data obtained during calibration was not affected by the
position of the control voltage jumper; therefore, a
visual inspection was the only means to ensure proper
placement of the control voltage jumper.
The licensee has agreed to write a special report concern-
ing this event. Preliminary discussions with the licensee
indicated that corrective actions to prevent recurrence
consist of writing a permanent procedure with a check-off
to ensure proper placement of the control voltage jumper
and performing the calibrations on site. This area will
remain unresolved until the inspector reviews the special
report that is expected to be issued in February 1986
(289/86-01-02).
3.2 Partial Loss of ICS/NNI power
3.2.1
Event Chronology
At 11:24 a.m. on January 24, 1986, a 30 amp Integrated
Control System (ICS) auto power (subfeed) breaker tripped
open causing a loss of auto power to all ICS Bailey
control stations. The plant was at 100% power
steady-state conditions with the ICS in auto control.
At the time, maintenance was being performed on a feed-
water flow transmitter that is powered from ICS auto at
the time.
Both feedwater pumps ran back to approximately 4100 rpm as
designed, causing a small reduction in feedwater flow to
the Once-Through Steam Generators (OTSGs). As feedwater
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flow and OTSG level decreased slightly, Reactor Coolant
System (RCS) pressure and Tave began to increase while
main steam / turbine header pressure decreased.
Numerous alarms in the control room sounded, including a
" Reactor Trip" alarm. A determination was made that the
reactor and turbine had not tripped, but a loss of ICS
auto power had occurred.
RCS pressure was reduced by manually opening the pressur-
izer spray valve and loss of main steam header pressure
was reduced by manually closing the turbine control
valves. After the plant was stabilized, EP 1202-42,
" Total or Partial Loss of ICS Auto Power," was reviewed to
ensure that all immediate and followup actions were
performed. As a result, in accordance with the procedure,
the pressurizer heater low level interlock was bypassed
for RCS pressure control.
Personnel were then dispatched
to determine which breaker had tripped. Work on the flow
transmitter was terminated.
The breaker was closed at 12:38 p.m. and ICS auto power
was restored, after the ICS demand signals for the main
feedwater pumps (MFPs) had been readjusted so that a plant
transient would not occur when the breaker was closed.
All ICS stations were placed in automatic and the plant
was returned to 100% power.
3.2.2
Event Review
The inspectors reviewed the event to determine the follow-
ing information:
--
details regarding the cause of the event and event
chronology;
consistency of licensee actions with license require-
--
ments, approved procedures and the nature of the
event;
--
operator response to the event; and,
--
follow-up licensee actions to prevent or reduce
recurrence of the event.
As part of the review, the inspectors had discussions with
cognizant licensee personnel, reviewed various emergency
and alarm response procedures, and reviewed Plant Incident
Report No. 1-86-01.
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3.2.3
Licensee Findings
The first indication of a plant transient was a reactor
trip alarm, loss of ICS auto power alarm, and several
other alarms. The loss of ICS auto power causes the
reactor trip alarm; the alarm response procedure also
reminds the operator that a reactor trip alarm occurs when
ICS auto power is lost. By training, operators are
instructed to determine the validity of the reactor trip
alarm before entering ATP 1210-1, " Reactor Trip."
Stooilizing turbine header pressure at a lower pressure
was a significant action because sufficient reduction in
feedwater flow to the OTSGs was realized when the MFPs ran
back to 4100 rpm. Therefore, power was stabilized at 97%
with an elevated Tave. Opening the pressurizer spray
valve restricted increase in the RCS pressure to 2285
psig.
(Reactor trip setting was 2300 psig.)
Design features of the ICS enabled the operators to stabi-
lize the plant quickly. Operators were able to switch
certain transmitters to hand power so that indication
would not be lost, while other ICS control stations failed
as is when the 30 amp breaker opened.
EP 1202-42
adequately identified the failed indicators and other
alternate indicators available for plant control.
During the event, a PORV tailpipe temperature alarm was
received along with indication of a perturbation in the
RCS drain tank level.
The licensee believes a spurious
signal caused the PORV to open for approximately 0.2
seconds. No significant RCS depressurization was ob-
served.
After controlled and deliberate troubleshooting of the 30
amp ICS auto power breaker was performed, it was closed.
Verifying MFP ICS demand signals prior to closing the
breaker ensured a minimal system perturbation.
In addi-
tion, the sliding links for the feedwater flow transmitter
were verified open in case it hao caused the breaker to
trip. When the breaker was closed, test equipment indi-
cated normal current readings.
Initially, licensee representatives believed that the
feedwater flow transmitter caused the 30 amp ICS auto
breaker to open because the transmitter was being powered
!
- up when the transient occurred and it was also located
in the same cabinet as the breaker. However, subsequent
l
testing of the transmitter did not reveal any problems.
After additional troubleshooting was performed, a loose
wire on the 30 amps ICS auto breaker was found. This
i
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l
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,
.
16
apparently caused the breaker to open. As an additional
measure, the licensee checked other breakers for loose
wires.
The licensee stated that there it a potential for ICS
failures during maintenance activities in the ICS cabi-
nets. Therefore, when work is to be performed on the
ICS, the following will be observed:
the shift supervisor will be shown the scope of work
--
using appropriate prints;
headphone communications will be established between
--
the control room and the ICS work location; and,
at least four main areas of the console will be
--
continuously manned.
The licensee's initial review of the transient has pro-
posed the following corrective actions.
--
Review of the light indications for a loss of ICS
auto power. The licensee felt there was an inconsis-
tency in the design logic of the system.
Develop ICS maintenance procedures that identify
--
upstream fuses and/or breakers that could be affected
by the maintenance activity.
Initiate an engineering change so that MFP ICS signal
--
shaping modules are powered from hand rather than
auto.
--
Review and revise, if appropriate, the power supply
for the reactor trip alarm relay.
Incorporate any lessons learned from the incident
--
into the emergency procedures (EP 1202-40,41,42).
--
Provide clear guidance on restoring ICS to auto from
hand while at power in OP 1105-4.
--
Test and replace, as necessary, the 30 amp ICS auto
breaker.
Technical Functions Division will provide an indepen-
--
dent review of the plant incident.
.
- _,
---
.- - .
.
.
.-. .-
_ .-
.
17
,
3.2.4
NRC Findings
The operators' performance during the transient was very
good. There were a number of times when inappropriate
operator action, had it occurred, would have worsened the
transient. Good operator performance reflects proper
training and preparation.
Careful planning by the
licensee before closing the 30 amp ICS breaker prevented a
transient from occurring due to runup of the MFPs.
Modifications to the ICS performed dur ng the last several
i
years were very important to the successful response of
the plant to the transient.
Except for the MFPs running
back to 4100 rpm, all other major ICS equipment failed as
is; also, indicators. automatically had backup power
available.
Procedures were good and provided adequate guidance to the
operators during the transient. However, several proce-
dural improvements are planned to be incorporated by the
licensee.
The inspector's review of licensee corrective action
revealed that the operators understanding of the light
indications associated with the ICS were deficient. By
training, the operators believed that the subfeed au-
to/ hand light should have been out, not the ICS auto
light. A memorandum from the Plant Operations Supervisor
to shift supervisors, dated February 6,1986 (Serial No.
3210-86-0038), discussed a console indication labeling
upgrade for a loss of ICS/NNI power.
In this memorandum,
specific information dealing with the ICS light indication
response to the various breaker trips was discussed. The
memo supported the light-out indication for the ICS auto
light.
The information contained in the memo was dis-
cussed with all the operating crews. The inspector
considered this action adequate.
The licensee agreed to provide a special report on this
event.
The remaining open licensee actions, including the
special report to the NRC, will remain unresolved and will
be reviewed in a subsequent inspection (289/86-01-03).
3.3 Conclusion
These events, in particular the loss of ICS power event, confirm
previous NRC conclusions of excellent operator performance as a
result of a substantial training program.
There apparently was
still some confusion among licensed operators on the proper response
of the loss of ICS/NNI power indicating light system, but this did
.
_
.
18
.
not affect the response to avoid a safety system challenge.
Pending a review of the subject reports, appropriate corrective
actions were proposed or implemented by the licensee.
The RPS breaker event substantiated already identified weaknesses in
the licensee's program for independent verification of equipment
control activities (re: NRC Inspection Report No. 50-289/85-27).
4.
Independent Technical and Safety Review
Facility Technical Specifications (TS) 6.5.1 and 6.5.2 specify the
requirements for Responsible Technical Reviews (RTR) and Independent
Safety Reviews (ISR) of various activities identified in these TS.
During this inspection, the licensee's compliance with these requirements
was reviewed. The specific requirements reviewed and the results of the
review are as follows.
4.1 Division Review and Approval Responsibility
The TS require that each division within the GPU Nuclear Corporation
be responsible for performing RTR and ISR of areas assigned in the
GPUN Review and Approval Matrix. To implement this requirement, a
number of procedures have been developed. The Corporate Procedure
1000-ADM-1291.01, GPU Nuclear Safety Review and Approval Procedure,
has been prepared to control and implement the GPUN safety review
and approval process.
This procedure applies to each division /
facility of GPUN. This procedure makes each Division Vice President
responsible for the development and implementation of divisional
procedures to support the requirements of the corporate procedure.
These divisional procedures have been developed and are identified
as follows:
--
Technical Functions Division, Procedure 5000-ADM-1291.02,
Independent Safety Review;
Nuclear Assurance Division, Procedure 6000-ADM-1291.01, Perfor-
--
mance of Safety Reviews;
Radiological and Environmental Control Division, Procedure
--
9000-ADM-1291.01, Radiological and Environmental Controls
Division Safety Review and Approval Procedure; and,
Three Mile Island Division, Procedure 1034, Plant Review Group.
--
A review of the corporate procedure verified that adherence to this
procedure would ensure compliance with the TS requirements for RTR
and ISR. No specific review was performed on each of the individual
division procedures (except in the area of reports to the division
vice presidents), nor were any requirements of the procedures which
are in addition to TS requirements verified by the inspector.
I
.
19
.
Many of the specific review requirements of the TS are specified in
a GPUN review and approval matrix which is a part of corporate
procedure 1000-ADM-1291.01.
Specific activities described by the
review and approval matrix were selected for review in order to
verify that each division was performing as required. The following
specific subjects requiring review were verified:
Gener al Plant Operating Procedures -- Verified procedures
--
1103 1, " Reactor Coolant Inventory Tracking System" and
1104-45J, " Combustible Gas / Heat Activation Device," received
RTR and ISR by cualified THI-1 and Technical Function Division
personnel, as recuired;
Emergency Operating Procedures -- Verified procedures 1202-12,
--
" Excessive Rad Levels" and 1202-40, " Total Loss of Power to
ICS/NNI," received RTR and ISR by qualified TMI-1 and Technical
Functions Division personnel, as required;
--
Fire Protection Operating Procedures -- Verified procedure
1104-45E, " Fire Service Protection System," received RTR and
ISR by qualified TMI-1 Division personnel;
--
Calibration Procedures -- Verified Procedure 1430-MU-1, " Seal
Leakoff Transmitter Flow Calibration," received RTR and ISR by
qualified TMI-1 Division personnel.
Preventive Maintenance Procedures -- Verified procedure IC-133,
--
" MAP-5 Post-Accident Iodine and Particulate Samples," received
RTR and ISR by qualified TMI-1 Division personnel;
Corrective Maintenance Procedures -- Verified Procedure
--
1410-P-9, " Adjusting MU Pump Mechanical Seals,: received RTR
and ISR by qualified TMI-1 Division personnel.
Surveillance Procedures -- Verified Procedures 1302-17.4,
--
"RM-L-12 Calibration," and 1303-11.39, " Emergency Feedwater
Pump Auto Start," received RTR and ISR by qualified TMI-1
Division personnel.
--
Radiological Controls -- Verified procedures 9100-ADM-4000.06,
9100-PLN-4200.01, and 9100-IMP-4250.08 and Procedure Change
Requests (PCRs) 1-RC-85-0103,1-RC-85-0088, and 1-RC-85-0045
received RTR and ISR by qualified radiation controls personnel;
--
Environmental Monitoring Procedures -- Verified procedures
9420-SUR 4523.05, " Determination of REMP Investigational Levels
and Subsequent Actions," 9420-IMP-4522.12. "REMP Sample Collec-
tion Procedure," and 9420-SUR-4570.01, "TMINS Hydrographic
Survey," received RTR and ISR by qualified radiological con-
trols personnel;
-
..
20
Emergency Plan Implementing Procedures -- Verified TCN
--
1-86-0002 to 1004.2, " Emergency Directions," TCN 1-85-0179 to
1004.4, "Callout of Duty Roster Personnel," TCN 1-85-0193 to
1004.5, " Communications and Record Keeping," and PCR
1-EP-86-0008 to 6415-IMP-1300.10, "Onsite/0ffsite Radiological
and Environmental Monitoring," received RTR and ISR by quali-
fied members of the Emergency Preparedness Department;
Security Plan and Implementing Procedures -- Verified the
--
security plan and procedure 7000-ADM-1291.01, " Performance of
Safety Reviews," received RTR and ISR by qualified security
personnel;
Quality Assurance Plan and Implementing Procedures -- Verified
--
the GPUN Operational Quality Assurance Plan and procedures
1000-ADM-7215 01, "Important-to-Safety Material Nonconformance
Reports," anc 1000-ADM-7215.02, "GPUN Quality Deficiency
Reports" received RTR and ISR by qualified Nuclear Assurance
Division personnel;
Process Control Program Implementing Procedures -- Verified
--
procedure 1104-281, " Process Control Program - Hittman," and
1104-28D, " Packaging Non-Compactible Trash," received RTR and
ISR by qualified TMI-1 division personnel;
Offsite Dose Calculation Manual Implementing Environmental
--
Controls Procedures -- Verified procedures 9420-IMP-4522.02,
"REMP Sample Collection Procedures TLDs," and 9420-IMP-4522.03,
"REMP Sample Collection Procedure Fish, Aquatic Sediment,
Aquatic Plants," received RTR and ISR by qualified
Environmental Controls personnel;
--
Special Temporary Procedures (STP) -- Verified STP No.
1-85-0048, " Main Generator Manual Excitation Test," and STP No.
1-85-0050, "0TSG A/B Blowdown," received RTR and ISR by
qualified TMI-1 Division personnel;
Technical Specifications / License Change Requests -- Verified
--
Technical Specifications Change Requests 127, 128, and 133
received RTR and ISR by qualified Technical Functions personnel
or by qualified reviewers from other divisions as permitted by
procedure 1034, " Plant Review Group;"
--
Licensee Event Report (LER) -- Verified LER 85-001-0,
" Inadvertent ESAS Actuation," and LER 85-002, " Manual Reactor Trip Due to Fire in the Control Rod Drive Transfer Switch,"
received RTR and ISR by qualified TMI-1 and Technical Functions
.
Division personnel;
!
_
.
21
-
Review of Written Summaries of Audit Reports -- Verified GPUN
--
Audit Reports S-TMI-85-03, "TMI-1 and TMI-2 Radwaste
Management," and S-TMI-85-11, TMI-1 Operations," received
reviews as required by Section IV of the TMI-1 Review and
Approval Matrix;
--
Investigation of Violations of Technical Specifications -- The
Plant Review Group (PRG) is currently reviewing violations of
TS. Examples of violations of TS being reviewed by the PRG are
Quality Deficiency Report SRC-049-85, dealing with oxygen
concentration in the reactor coolant system, TCN 1-86-0005 not
being reviewed within 14 days as required, and a missed
surveillance requirement on RM-A5.Section IV of the TMI
Review and Approval Matrix specifies certain specific
documentation requirements associated with the investigation of
violations of TS.
There appears to be no question that
violations of TS are being reviewed by qualified TMI-1 division
personnel as evidenced by PRG meeting minutes. However, the
documentation of these reviews is not as required by the notes
associated with Section IV of the Review and Approval Matrix.
Additional information relative to documentation is identified
in the following paragraph.
--
Review of Every Unplanned Release of Radioactivity to the
Environment -- The inspector reviewed Radiological
Investigation Report No.85-008, dealing with a small release
(.7 Ci) on October 28, 1985, resulting from makeup pump 1A
maintenance, Plant Incident Report No. 1-85-19, dealing with a
release (46.3 C1) on December 30, 1985, also resulting from
makeup pump 1A maintenance and Radiological Investigation
Critique minutes dealing with a small release (1.4 C1) on
December 17, 1985, resulting from gas compressor maintenance.
These documents show that releases of radioactivity to the
environment are being reviewed by qualified TMI-1 Division and
Radiation Controls Division personnel. As discussed above,
Section IV of the TMI Review and Approval Matrix specifies cer-
tain specific documentation requirements for reviews of every
unplanned release of radioactivity to the environment and
investigations of violations of TS.
Reviews of these items are
being conducted.
However, the documentation of these reviews
does not entirely satisfy the documentation requirements
specified in the matrix.
The licensee will more clearly define the method for documenting
the review of TS violations and unplanned releases. This item is
unresolved pending completion of licensee action as noted above and
subsequent NRC Region I review (289/86-01-04).
Also, included in
this unresolved item is that the licensee will also more clearly
define what constitutes an unplanned release of activity to the
__
.
22
.
environment which requires review under Section IV of the Review and
Approval Matrix and Section 6.5.1.10 of the Technical Specifica-
tions.
4.2 Reviewer Qualifications and Designation
The TS specify the qualifications for RTR and ISR.
Step 4.1 of
corporate procedure 1000-ADM-1291.01 requires "each divisional vice
president will be responsible for having ISR and RTR identified
within his organization."
The inspector serified that reviewers for RTR and ISR were designat-
ed in writing as follows.
Memo dated November 1,1985, from the PRG Chairman, TMI-1
--
designates the RTR and ISR for the THI-1 division.
--
Memo dated December 19, 1984, from the security manager desig-
nates the. Security Department RTR and ISR.
Memo dated October 7, 1985, from the safety review coordinator
--
designates the Quality Assurance Department, Training and
Education Department, Nuclear Safety Assessment Department, and
the Emergency Preparedness Department RTR and ISR,
--
Memo dated December 18, 1985, from a senior licensing engineer
identifies the safety reviewers for the Technical Functions
Division.
Memo dated December 5, 1985, from the Direct m.
Radiological
--
and Environmental Controls Division, designat,4 the Radiation
Controls - THI-1, Environmental Controls - TMI-1, Environmental
Controls - Corporate, and Radiation Engineering - Corporate
Technical and Safety Reviewers.
The TS specify safety reviewer qualifications. The corporate safety
Review and Approval Procedure specifies the same qualification
requirements and in addition requires training and retraining for
RTR and ISR.
The formal records documenting the qualifications and training of
reviewers are being maintained at the corporate office in
Parsippany. Sample unofficial records being maintained at the site
indicate that reviewer qualifications and training requirements are
being met.
For each of the specific items reviewed by the inspec-
tor, the RTR and ISR were verified as being on the list of qualified
reviewers.
i
23
.
4.3 Review Records
Technical Specification 6.5.1.13 requires records of RTR be main-
tained. Step 4.13.1.2 of the corporate procedure 1000-ADM-1291.01,
states " records of documents prepared, reviewed, and approved in
accordance with the GPU Nuclear Safety Review and Approval Matrix
will be maintained for the life of the operating license."
The format of the records maintained show that reviews are being
parformed in accordance with the Review and Approval Matrix vary
considerably among the various groups involved in performing re-
views. However, the inspector found that, for the specific items
reviewed, sufficient records are being maintained to show RTR and
ISR are being performed as required by the matrix. The quality of
these reviews will be subject to inspection in the future. Qualifi-
cation records were reviewed as noted in paragraph 4.2.
Technical Specification 6.5.2.7 requires that reports of ISR be
prepared, maintained and transmitted to the cognizant division vice
president. The corporate Safety Review and Approval Procedure
1000-ADM-1291.01 in Step 4.13.1.3 requires " Reports of all technical
reviews and independent safety reviews will be prepared and trans-
mitted to the responsible division vice president. They will be
maintained for the life of the operating license."
Neither the TS or the corporate procedure specify any time period
for submitting the report. Also, each of the division procedures
differ somewhat in their requirements relating to reports to the
division vice presidents. The requirement of each divisional
procedure and how each division complies with the requirement for
submitting a report to the vice president is as follows.
--
TMI-1 Division -- Procedure 1034 specifies " Reports of re-
views...shall be transmitted periodically to the vice presi-
dent, the Operation? and Maintenance Director, and the Plant
Engineering Directoe of TMI-1."
Reports of reviews by the
TMI-1 division are transmitted to the vice president by the
forwarding of Plant Review Group meeting minutes and by Weekly
Plant Review Group supplementary reports.
--
Technical Funct'.ons Division - The Technical Functions Proce-
dure 5000-ADM-1291.02 specifies " Engineering Services shall
prepare reports of reviews for each plant annually.
These
reports shall be retained at the corporate storage area and
copiet, transmitted to the vice president, Technical Functions,
and tre cognizant plant vice president. Each report shall be a
summary of Independent Safety Reviews conducted; it will
include irregularities and a listing of all reviews conducted
during the period, by subject, as listed in the Review and
Approval Matrix." One report of reviews was prepared by a
.
24
.
senior licensing engineer. This report, dated April 19, 1984,
covers the period August 28, 1982, to April 1984.
The report
is approximately 75 pages in length and, basically, lists
the procedures and other items reviewed by Technical Functions.
Also, a report dated March 15, 1985, identified as 1984 Annual
Report - Safety Review Process is a two page report which
summarizes the reviews conducted during 1984.
The report also
summarizes minor administrative deficiencies noted.
Nuclear Assurance Division -- The Nuclear Assurance Division
--
Procedure 6000-ADM-1291.01 in the Records Section, Step,
4.13.1.3 states " Copies of all safety evaluations developed by
Nuclear Assurance or where Nuclear Assurance performed the
Independent Safety Review will be sent to the Nuclear Assurance
Safety Review Coordinator (NASRC).
The NASRC will assure they
are maintained for the life of the operating license."
In
accordance with this procedural requirement, the site QA and
Emergency Preparedness groups forward reports of reviews they
perform to the Nuclear Assurance Safety Review Coordinator.
Although the Nuclear Assurance Division Procedures do not
require a report to the responsible division vice president, a
report dated April 11, 1984, was submitted to the responsible
vice president.
This report summarized reviews performed since
the process started in August 1982 until April 1984. This
report stated it was submitted in accordance with the corporate
procedural requirement. Although no procedural guidance was
provided, the report summarized the reviews that were done by
document type and number and also identified certain trends
and/or problems identified.
Administration Division - The Administration Division Procedure
--
7000-ADM-1291.01 requires " Reports of all Technical Reviews and
Independent Safety Reviews will be prepared and transmitted to
the Division Director - Administration. They will be main-
tained for the life of the operating license." A report which
lists all safety reviews vhich have been performed of
Administration Division documents since the inception of the
safety review system in August 1982 was submitted to the respon-
sible vice president on February 19, 1985.
Radiological and Environmental Control Division - The Radio-
--
logical and Environmental Controls Division Procedure
9000-ADM-1291.01 in Step 5.7 requires "A summary of the respon-
sible technical reviews and the independent safety reviews
performed by THI-1 and Oyster Creek R&EC Division personnel
shall be forwarded to the vice president, R&EC, on a semi-annual
oasis." Although the procedure specifies a summary of RTR and
ISR be forwarded to the vice president on a semi-annual basis,
the Radiological Controls Group lists reviews performed in a
Radiological Controls Monthly Status Report. Also, a different
group in the same division, the Radiological and Environmental
i
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l
l
[
.
25
.
Controls Group, in response to an April 1984 audit finding
which identified the group's failure to provide the required
report to the vice president, committed to providing a summary
report of reviews to the vice president on a semi-annual basis
as the division procedure requires. During this inspection, it
was noted these semi-annual reports had not been submitted.
Prior to the conclusion of the inspection, a report of Technical
and Safety Reviews performed by TMI Environmental Controls
personnel during 1985 was submitted. This three page report
only listed the procedures / documents reviewed. The licensee
felt this report satisfied the TS requirement.
As can be seen from the above, in the absence of any specific
guidance, the frequency at which the required report is submitted to
the responsible vice president varies considerably from division to
division and also the content of the reports varies from a
listing of documents reviewed to an analysis of the reporting
division's review process.
These problems were discussed with licensee representatives. The
licensee representatives stated the Corporate Safety Review and
Approval Procedure 1000-ADM-1291.01 is currently in the process of
being reviewed and that to correct the problems identified during
this inspection, the revision to the procedure will address both the
frequency and the content of the reports to the cognizant division
vice president. This revision to the procedure will be issued by
June 30, 1986. This item is unresolved (289/86-01-05).
4.4 Conclusion
The licensee's review and approval system is complex; but, overall,
TS requirements are satisfied by each of the divisions. How that
goal is achieved is diverse among the divisions. The reports of
reviews could be enhanced by a more consistent and unified approach
based on corporate guidance. NRC Region I will continue to
review this area with respect to unresolved items noted above and
with respect to quality of these reviews.
5.
Outage Planning and preparation
As part of the health physics programmatic review, the inspector reviewed
the special preparations for the next outage that will involve signifi-
cant health physics related work. Presently, the next scheduled evolu-
tion is an eddy current inspection scheduled in March 1986.
Discussions with the Radiological Field Operations supervisory staff
indicate that planning and preparations for the upcoming March outage
have been initiated in a timely fashion.
Representatives from the
Radiological Controls department have been involved in preliminary outage
planning meetings.
i
"
_
_ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _____ _ _ _ _ _ _ _ _ __
-
.
26
'
The licensee indicated that in plant health physics (HP) technician staff
will not be augmented with contractor personnel during the outage. The
HP staff will be supplemented by discontinuing the cyclic training shift,
which normally requires a percentage of the staff to be in training.
Shift coverage during steam generator work will be split into two 10-hour
work shif ts and a single 4-hour cleanup shif t.
The cleanup shift will be
devoted to decontamination and housekeeping efforts in support of outage
activities.
Additional licensee preparatory effort has included:
designation of a responsible individual establishing an outage
--
control point on the 306-foot elevation of the intermediate
building;
scheduling a pre-outage calibration of instrumentation that will
--
become due for calibration during the outage; and,
scheduling pre-outage qualification boards for all technicians who
--
will become due for requalification during the outage.
The inspector reviewed licensee surveys and posting of several
newly-developed hot spots in the hallway adjacent to mini-valve alley
in the auxiliary building. The hot spots were created when radioactive
resin from a makeup and purification system demineralizer was inadver-
tently introduced into a waste gas header (see paragraph 2.2.4).
Current surveys of the alley and hallway reflecting the new
radiological conditions were available at the control point and the
technician performing the surveys appeared knowledgeable in general
survey practices and techniques. Shielding and posting efforts in the
hallway outside the alley were found to be adequate.
6.
Security Program and Implementation
6.1 MC 81018 - Security Plan and Implementing Procedures
The licensee was adhering to the Modified Amended Physical Security
Plan (MAPS) for Three Mile Island Nuclear Station, Units 1 & 2,
Revision 21, dated January 7, 1986.
Implementing procedures were
reviewed and were adequate to satisfy the general performance
requirements and objectives of 10 CFR 73.55. No unauthorized
changes were identified.
6.2 MC 81020 - Management Effectiveness
The inspectors interviewed and observed members of the security
force and found that they were knowledgeable of their duties and
appeared very professional.
Since the last inspection, the licensee
has made the following changes or upgrades to security equipment:
.
27
-
THIS PARAGRAPH CONTAINS SAFEGUARDS INFORMATION
AND IS NOT FOR PUBLIC DISCLOSURE, IT IS
INTENTIONALLY LEFT BLANK.
.
Quarterly management meetings are held between the two GPU Nuclear
sites and the corporate headquarters in Parsippany, New Jersey.
These meetings aid in keeping upper level management aware of
current issues and problems so that they may assist lower level
management and keep them informed of current trends and future
plans.
6.3 MC 81022 - Security Organization
The licensee's security management structure and chain of command
were reviewed by the inspectors and found to be in conformance with
the approved physical security plan, contingency plan, and imple-
menting procedures. The licensee's response to several actual
contingencies and one simulated contingency was observed by the
inspectors and was found to be adequate.
6.4 MC 81038 - Records and Reports
Weekly and quarterly security equipment test records were reviewed
by the inspectors and found to have been accomplished in accordance
with the physical security plan. A review of Security Event Report
No. 85-01, dated January 20, 1985, disclosed that it was timely and
complete.
6.5 MC 81042 - Testing and Maintenance
The testing and maintenance program for security equipment conformed
to the physical security plan and implementing procedures. The
inspectors observed the testing of intrusion and access control
equipment and found the systems acceptable.
.
.
28
-
6.6 MC 81046 - Locks, Keys, and Combinations
The inspectors observed the key and lock custodian conduct a securi-
ty key inventory and a test of the card key system. All security
keys were accounted for in accordance with the security plan and
licensee procedures.
6.7 MC - 81052 - Physical Barriers (Protected Areas)
The inspectors verified by observation that the PA physical barriers
were maintained by the licensee in accordance with the physical
security plan.
6.8 MC 81054 - Physical Barriers (Vital Areas)
The inspectors toured the vital areas and verified by observation
that the licensee was maintaining the physical barriers surrounding
the vital areas in accordance with the physical security plan.
THIS PARAGRAPH CONTAINS SAFEGUARDS INFORMATION
AND IS NOT FOR PUBLIC DISCLOSURE
IT IS
INTENTIONALLY LEFT BLANK.
6.9 MC 81058 - Security System Power Supply
The inspectors determined that the licensee was maintaining an
adequate uninterruptible power supply system to provide emergency
power to physical security equipment in accordance with the physical
security plan.
The inspectors verified, through a review of weekly
and quarterly test and maintenance records, that the power supply
system was tested at periodic intervals.
6.10 MC 81064 - Compensatory Measures
The inspectors determin1d by reviewing records that compensatory
measures conformed to the physical security plan and implementing
procedures.
Security personnel demonstrated adequate knowledge of
compensatory measures when interviewed by inspectors.
THIS PARAGRAPH CONTAINS SAFEGUARDS INFORMATION
AND IS NOT FOR PUBLIC DISCLOSURE, IT IS
INTENTIONALLY LEFT BLANK.
.
.-
.
_. .
. -.
.-
.
.
29
.
6.12 MC 81070 - Access Control (Personnel)
The inspectors determined that the licensee was maintaining
personnel access control to the PA and VA in conformance with the
physical security plan and implementing procedures.
6.13 MC 81072 - Access Control (Packages)
The inspectors observed the search process at the entry control
points into the PA and verified that packages and material were
being processed into the PA in conformance with the physical securi-
ty plan and implementing procedures.
6.14 MC 81078 - Detection Aids (Protected Areas)
The licensee demonstrated to the inspectors that the intrusion
detection system (IDS) would detect penetration tests of the PA in
conformance with the security plan and implementing procedures.
6.15 THIS PARAGRAPH CONTAINS SAFEGUARDS INFORMATION
AND IS NOT FOR PUBLIC DISCLOSURE, IT IS
INTENTIONALLY LEFT BLANK.
6.16 MC 81084 - Alarm Stations
Observation by the inspectors of the operations and tests of equip-
ment in the central and secondary alarm stations verified that the
licensee was maintaining them in accordance with the security plan
and implementing procedures.
6.17 MC 81088 - Communications
The inspectors confirmed by observing tests and by interviewing
central and secondary alarm station operators that the licensee was
maintaining internal and external communications in conformance with
the security plan and implementing procedures.
6.18 MC 81501 - personnel Training and Qualification
The licensee's training and qualification (T&Q) program was found by
the inspectors to be implemented as outlined in the T&Q plan.
However, Enclosure 2 to Revision 6, dated August 7, 1984, omits the
conditions or standards for task 1.3, " Directs Site Protection
Force," which is a task listed in Enclosure 1.
The licensee advised
that the omission has been identified and is included in a proposed
.
30
.
revision (No. 7). The revision is currently in the review process
and it will correct this omission. A random review of 25% of the
training records reflected that training and qualification or
requalifications were current.
6.19 MC 83601 - Safeguards Contingency Plan
The inspectors determined that the licensee's program for responding
to security threats and other contingencies as outlined in the
Safeguards Contingency Plan (SCP) and its implementing procedures
was adequate. The inspectors observed the security force respond,
in accordance with the SCP, to several alarms and to one simulated
contingency.
No deficiencies were noted.
6.20 Conclusion
Based on this sampling review, the licensee has complied with the
plan and is adhering to implementing procedures.
7.
Fire Protection / Prevention
,
The inspector reviewed several documents in the below listed .reas of the
program to verify that the licensee had developed and implemented ade-
quate procedures consistent with the Fire Hazard Analysis (FHA), Final
Safety Analysis Report (FSAR), and Technical Specifications (TS). The
documents reviewed, the scope of review, and the inspection findings for
each area of the program are described in the following sections.
7.1 Program Administration and Organization
'
The inspector reviewed the following licensee documents:
Technical Specifications, Section 6, Administrative Controls;
--
Administrative Controls - Fire Protection Program Procedure
--
No., 1038, Revision 11; and,
Fire Protection Evaluation, Procedure 5000-ADM-7370.01
--
(EP-013), Revision 2.
The scope of review was to ascertain that:
personnel were designated for implementing the program on site;
--
and,
qualifications were delineated for personnel designated to
--
implement the program.
No unacceptable conditions were identified.
w-
-
w
31
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i
7.2 Admir.istrative Control of Combustibles
The ,r.spector reviewed the following licen ee documents:
" Control of Transient Combustible Materials," Administrative
--
Procedure No. 1035, Revision 11; and,
(
" Good Housekeeping," Administrative Procedure 1008, Revistor.
--
14.
The scope of review was to verify that the licensee had developed
administrative centrols which included:
special authorization for the use of combustible, flammable, or
--
explosive hazardous material in safety-related areas;
prohibition on the storage of combustible, flammable, or
--
explosive hazardous material in safety-related areas;
the removal of all wastes, debris, rags, oil spills, or other
--
combustible materials resulting from work activities or at
3
the end of each work shift, whichever is sooner;
all wood used in safety-related areas is to be treat;d with
--
flame retardant;
periodic inspection for accumulation of combustibles;
--
transient combustibles to be restricted and controlled in
--
safety-related areas; and,
housekeeping to be properly maintained in areas containing
--
safety-related equipment and components.
No unacceptable conditions were identified.
7.3 Administrative Control of Ignition Sources
The inspector reviewed Maintenance Procedure 1410-Y-26, " Control of
Hot Work," Revision 12. The scope of review was to verify that the
licensee had developed administrative controls which included:
requirements for special authorization (work permit) for
--
activities involving welding, cutting, grinding, open flame ,
or other ignition sources and that they 3re properly safeguard-
,
ed in areas containing safety-related equipment and components;
i
and,
. . . . .. _
__
_
_
.
32
.
prohibition on smoking in safety-related areas, except where
--
" smoking cormitted" areas had been specifically designated by
plant management.
The inspector observed that the referenced procedure is not clear in
the requirement for fire watchers to stay on location 30 minutes
aftGr the hot work is completed. The licensee stated that this is
the case at TMI. A procedure change was issued that clearly states
this requirement.
7.4 Other Administrative Controls
The inspector reviewed the following licensee documents:
Technical Specifications, Section 6, Administrative Controls;
--
and,
'
General Employee Training - Module IV, Fire Protection, Revi-
--
sion 1.
The scope of review was to verify that the licensee had developed
administrative controls which require:
work authorization, construction permit, or similar arrangement
--
is provided for review and approval of modification, construc-
tion, and maintenance activities which could adversely affect
the safety of the facility;
fire brigade organization and qualifications of brigade members
--
are delineated;
fire reporting instructions for general plant personnel are
--
developed;
periodic audits are to be conducted on the entire fire protec-
--
tion program; and,
fire protection / prevention program is included in the
--
Itcensee's QA program.
No unacceptable conditions were identified.
7.5 Equipment Maintenance, Inspection, and Tests
The inspector reviewed the following randomly selected documents to
determine whether the licensee had developed adequate procedures
which established maintenance, inspection, and testing requirements
for the plant fire protection equipment:
" Fire Pump Capacity Testing," Surveillance Procedure (SP)
--
3303-R2, Revision 6;
.
-_
.
__
. _ _ _ -
.
33
+
"Hese Station Inspection," SP 1301-12.2, Revision 5;
--
" Fire Pump Periodic Operation," SP 3303-M1, Revision 13;
--
" Diesel Fire Pumps Battery Check," SP 3301-Q2, Revision 8;
--
" Fire System Diesel Battery Check," SP 33Cl-W2, Revision 4;
--
" Fire Protection Instrumentation Non-Supervised Circuits Test,"
--
SP 1303-12.14, Revision 3;
" Fire System Valve Line Up Verification," SP 3301-hl,
--
Revision 20; and,
" Fire Pump Diesel Fuel Sampling," SP 3303-Q1, Revision 9.
--
In addition to reviewing the above documents, the inspector reviewed
the maintenance / inspection / test records of the procedures listed
above to verify compliance with Technical Specifications and estab-
lished procedures.
No unacceptable conditions were identified.
7.6 Fire Brigade Training
7.6.1
Procedure Review
The inspector reviewed the following licensee procedures:
" Fire Brigade Training Administrative Program,"
--
Administrative Procedure 6210-ADM-2620.03;
" Administrative Controls, Fire Protection Program,"
--
AP 1038; and,
Amendment 44 to Facility Operating License No.
--
ORP-50.
The scope of review was ',o verify that the licensee had
developed administrative procedures which included:
requirements for announced and unannounced drills;
--
requirements for fire brigade training and retraining
--
at prescribed frequencies;
requirements for at least one drill per year to be
--
performed on a "backshift" for each brigade; and,
i
,
_
- _ _
_ - _ _ _ _ .
__
._
_ _ _ _
.
34
.
'
requirements for maintenance of training records.
--
No unacceptable conditions were identified.
7.6.2
Records Review
The inspector reviewed training records of fire brigade
i.
members for calendar years 1985 and 1986 to ascertain that
they had attended the required quarterly training and
participated in a quarterly drill, and received the annual
hands-on fire extinguishment practice.
In addition to the
records reviewed, the inspector witnessed a fire drill.
No unacceptable conditions were identified, except as
follows.
7.6.3
Fire Brigade Training Findings
7.6.3.1
Fire Brigade Training Violates T.S. Requirements
The inspector requested to observe a fire brigade drill
,
scheduled to be performed during the inspection.
The
inspector positioned himself by the firefighter's equip-
ment locker expecting that the firefighters would don
their protective gear responding to the drill. The senior
'
resident inspector observed activities at the scene.
>
Upon announcing the drill, only one fire fighter came to
,
the locker. The remainder of the brigade responded to the
scene of the fire and proceeded to simulate fire extin-
l
guishment.
j
'
The inspector noted that no one was wearing respiratory
'
protective equipment. THI-l T.S. 6.4.2 requires that the
training of the brigade shall meet or exceed NFPA
Standard No. 27(1976 edition) training requirements.
,
!
This standard requires the use of respiratory protective
equipment during drills.
j
'
A review of the licensee's procedures for fire emergencies
and drills identified that these procedures do not have
the requirements to respond to drills wearing respiratory
protection.
This is an apparent violation of the training requirements
identified in NFPA 27 included in T.S. 6.4.2
,
(289/86-01-07).
.
,
__
- _ _ _ _ _ _ . _
_ _ . _ _ _ _ _ _ _ _ _ . . _ ~ _ _ _ _ _ _ - - - - _ - - _ _ _ _ _ _ _ _ _ _
__
_
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e,
35
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7.6.3.2
Inadequate Fire Brigade Training Record Keeping
The inspector reviewed the fire brigade training records
to ascertain compliance with licensing conditions set
forth in a letter to NRC, dated January 7,1984 (Hukill to
Stolz).
This letter iterates the revised fire protection
program plan for TMI-1 and is a licensing basis document.
One requirement of the fire protection program is that
fire brigade members should participate in drills quarter-
ly but must participate in at least two drills per year.
The inspector observed that the method used to track the
training given to firefighters is cumbersome and mistake
prone.
In reviewing less than a 10*4 sample of firefighter
training, it was observed that few firefighters had
fulfilled the drill attendance requirement "at regular
intervals" for the year by participating in drills sched-
uled only a month apart. Existing NRC guidance specifies
that drills be scheduled at regular intervals. The same
t
review also identifiec' one firefighter on the brigade
eligibility list who did not have the required number of
drills. The inspector noted that the licensee utilized &n
inefficient record keeping system. The inspector also
noted the large size of the fire brigade. The inspector
questioned the relationship between the cumbersome record
keeping system, the large brigade size and the problems
with attendance at fire drills. The &bove are collec-
tively recognized as an unresolved item pending a detailed
review of the licensee's training procedures in this arei
g
by Region I (289/86-01-08).
7.7 Facility Tour
The inspector examined fire protection water systems, including fire
pumps, fire water piping and distribution systems, post-indicator
valves, hydrants, and contents of hose houses. The inspector toured
accessible vital and non-vital plant areas and Axamined fire detec-
tion and alarm systems, automatic and manual fixed suppression
systems, interior hose stations, fire barrier penetration seals, and
fire doors. The inspector obserted general plant housekseping
conditions and randomly checked tags of portable extinguishers for
evidence of periodic inspections. No deterioration of equiptent was
noted.
The inspection tags attached to extir:gvishers indicated that
monthly inspections were performed.
No unacceptable conditions were identified, e.xcept as follows.
,
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36
7.7.1
Inoperable Fire Ocors
The inspector observed that a number of doors labeled " fire
doors" would not close automatically. The licensee explained
that this is caused by air pressure differentials.
The lit.enses
committed to identify the doors involved af.d, if these doors
are ih fire walls, they will gither be fixed or other compensa-
tory measures Hill be taken in accardance yith the 10 require-
ments. This is an uaresolved item (289/B6-01 09).
In response to an NRC security inspector' cor/;ern, the licensee
initiated work on security doors that were also fire doofi (see
paragraph 6.8).
Apparently, fire protect.icrz personnel were not
factor'ed i,to the pro-job planning phase and those actions
would have decated the fire door,
Subsecuent to identification
cf the problein by a liSnsee operations engineer, appropriate
corrective action was taken to maintain the door for both fire
and security purposes. The inspector concluded that the
operations engineer was quick to ider.tify the problem, but the
incident showed poor Job planning by the maintenance depart-
ment.
The inspector had no further questions in this area.
7.7.2
Fire Drill and_pg e Systems !_nicerability
For the fire drill observed by the inspector, the licensee
provided the inspector with the drill scenario.
The scenario
involved a fire in the pressurizer heater cabinets switchgear
located on the 322' elevation in tha turbine building.
The inspector was stationed by the fire locker waiting fcr the
drill to start. When the drill was announced, the inspector
was not able to hear the announcement and the fire alarm was
-
barely audible. Because of this system's malfunction, a member
of the fire brigade also did not hear the announcement and did
not respond.
The licensee became aware of the system'.s mal-
function and committed to have the system repaired and en-
hanced. The enhancerrent will include additional speakers to
cover all plant areas and procedures for system surveillance.
This is an unresolved item (289/86-01-10).
7.7.3
Fire Service Water use for__ Utility Purposes
The inspector observed that plant personnel are using water
f rom hose stations to backwash and flush equipment. NFPA does
not recommend tnis practice because prolonged operation of
centrifugal pumps at shut of f pressure or low flow rates may
prove harmful to the pumps.
Using the fire pumps in this
manner will require additional maintenance and surveillance.
Additionally, from a human factors engineering standpoint,
,
a.
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.. .. - _. -
..
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37
'
the operators may get used to seeing tne pump running; so, if
+
the pyTp starta tacause of either a broken main or due to a
fire, either conditicn reay not be quic9.ly diagaosed.
This is an unresolved item pending eviaw of the licensee's
actions in this area by NRC Region I (789/86-01-11).
.
8.
Licensee Event Report Onsjf.e__ Review
1
The inspector reviewed Licensee Event Report (LER) No. 85-004-0, which
was submitted to the NRC on Decenber 26, 1985, in accordence with 10 CFR 50.73. The LER described a breach of a fire barrier during mcdification
'
work to a makeup pump wall with a sealant or contir,uous fire watch post.ed
as required by TS 3.18,7.
Dueing this inspection period, the inspector reviewed the licensee's
submitted report on the ev6nt.
The report complied wf?.h 10 CFR 50.73 and
accur.ately reported the facts of the event, properly evaluated the event,
and accurately reflected the corrective actions taken. An underlylr.g
cause was that this was the first time in a number of years maintenance
}
personnel did this type of work which is normally performed by contrac-
tors. The event did point out a need for closer supervisory scrutiny by
the maintenance department and better comnunications with fire protection
personnel.
9.
Licensee Action on Previous Inspection Findings
(
The inspector reviewed licensee action on prevfous inspection findings to
ensure that the licensee took appropriate action in response to the
findings or by self-initiative and that the licensee's .acticn was timely.
9.1
THIS PARAGRAPH CONTAINS SAFEGUARDS INFORMATION
f
AND IS NOT TOR PUBLIC DISCLOSURE, IT IS INTENTIONALLY LEFT SLANK.
The inspectors observed the licensee test all zones of the system
and they functioned according to test precedures which confcrmed to
general perf-crmance requirements.
>
9.2 (Closed) Violation (289/85-11-01): Individual not preperly
processed into the protected area at the screenhouse area
'The security officer involved was appropriately disciplined. Ali
+
security of ficers were reinstructed on the correct procedure for
access centrol and signed a statement acknowledging this retraining.
During this inspection, the inspectors obssrved several security
officers process personnel into the PA at the screenhouse area and
all were processed in accordance with the licensee's security plan
and implementing procedures,
s
6
_
O
8
38
9.3 (Closed) Violation Q69/85-11-02):
Two security officers had not
completed annual physical fitness _ testing.
In January 1986, respon-
__
'sibility for scheduling physical fitness testing was transferred
from the Training Department to the Security Department to provide
better line control. A review by the inspectors on the status of
training disclosed that physical fitness testing was current.
0.4 (Closed) Unresolvsd (289/85-17-01):
Positive control of photo
badges and key cards'.
T W inspector init1.41Ty reviewed the
licensee's control of ptioto badges and key cards in Irispection
Reoort 289/85-17. The item was considered unresolved pending
fu'rther review of the applicable portions of the licensee's security
plan. This review was performed as part of a later inspection
(289/85-27-63). Durit.g this subsequent review, the inspector deter-
rained the unresolved item to te a violation.
This item is being
adr>inistratively closed and will be tracked as part of the noted
violation.
As a result of thi.s review, the inspector concluded that the licensee's
actions were timely and appropriate to adequately resolve these issues,
except as n6ted in paragraph 9 4.
Appropriate enforcement action was
taken in that case.
10. E/it interviey
The ir,spectors discussed f.he inspection scope and findings with the
lir.ensee management at a final exit interview conducted on February 7,
1986.
In addition, an interin exit interview cccurred in the security
area on January 30, 1986. The following licensee personnel attended the
final exit n.eeting:
G. Baker, Hanager, Environmental Controls, THI-I
J. Colitz, Phnt Engineering Director, TMI-1
J. Enders, Lieutenant, TM1-1 Security
C. Incorvati, THI-1 Audit Supervisor, Nuclear Assurance
D. taudermilch, Protection Trair.ing Supervisor, TMI-1
R. Neisiig, TMI-1 Cor.munications
M. Nelson, TMI-1 Review Program Supervisor
1. O'Connor, i.ead Fire Protection Engineer, TMI-1/2
S. Otto, THI$1 Licensing Engineer, Technical Functions
F. Perry, Manager, Support Tralr.ing, TMI-1
L. Ritter, Administrator II, Maintenance, TMI-1
M. Ross, Plant Opef ations Director, TMI-1
9. Sinegar, Administrator II, Maintenance, TMI-1
C. Smyth, Manager of Licensing, Technical Functions
R. Toole, Operations and Maintenance Director, TMI-1
H. Wilson, Preventive Maintenance Supervisor, THI-1
- --
r~
..
,
&
39
+
The inspection results, as discussed at the meeting, are summarized in
the cover page of the inspection report.
Licensee representatives
indicated that other than the security area none of the subjects dis-
cussed contained proprietary or safeguards information.
Unresol"vid Items are matters about which information is required in order
to ascertain whether they are acceptable items, violations, or devia-
tions. Unresolved item (s), discussed during the exit meeting, are
documented in paragraphs 2.2.3, 3.1.4, 3.2.4, 4.1, 4.3, 7.6.3.2, 7.7.2,
7.7.3, and 9.4.
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 THI-1 restart.
Inspector follow item (s),
discussed during the exit meeting, are documented in paragraphs 6.8 and
9.1,
s
i
3
L
%
%
%
'
s
%
4
'
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O
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ATTACHMENT I
ADDITIONAL RESIDENT INSPECTOR COVERAGE
',
The NRC inspectors assessed the adequacy and effectiveness of operating
'
personnel performance based on the inspectors' observations of operating
activities to determine that:
operators are attentive and responsive to plant parameters and condi-
--
tions;
plant evolutions and testing are planned and properly authorized;
--
procedures are used and followed 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 wher required;
backup instrumentation, measurement, and readings are used as appropriate
--
when normal instrumentation is found to be defective or out of tolerance;
logkeeping is timely, accurate, and adequately reflects plant activities
--
and status;
operators follow good operating practices in conducting plant operations;
--
and,
operator actions are consistent with performance-oriented training.
--
The inspectors' observations included, but were not limited to, those reactor
plant operation, maintenance, radiological controls and surveillance test
activities listed below:
Operations
--
Control room observation of Control Room Operators (CRO), Shift Foremen
(SF), and Shif t Supervisors (SS)
Observation of turnover between SFs and auxiliary operators (A0s)
--
Observance of CR0 and SF logs
--
Performance of plant shutdown and startup for bellows replacement ob-
--
served in control room
Operational review of hot spot flush
--
Inspection of plant soaces
--
L
e
b
o
Attachment
2
Maintenance
Maintenance associated with extraction steam line bellows replacement
--
Nondestructive examination of bellows
--
Reactor Protection System (RPS) Breaker shunt trip replacement
--
Radiological Controls
Locked high radiation doors
--
Radiation Work Permit posting
--
Weekly survey maps
--
Surveillance
RPS breaker testing and calibration
--
Power Operated Relief Valve surveillance data
--
>
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