ML20214J702
| ML20214J702 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 08/12/1986 |
| From: | Haverkamp D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20214J699 | List: |
| References | |
| LRP, NUDOCS 8608150137 | |
| Download: ML20214J702 (95) | |
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8 '10 NUCLEAR REGULATORY COMMISSIONI f[$'? . ,
" lg .- r, BEFORE THE PRESIDING BOARD ' . - ,
In the Matter of )
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INQUIRY INTO THREE MILE ISLAND ) Docket No. LRP UNIT 2 LEAK RATE DATA FALSI- ) FICATION ) TESTIMONY OF DONALD R. HAVERKAMP Q.1 Please state your name, position and business address. A.1 fly name is Donald R. Haverhamp. My position is Project Engi-neer, Reactor Projects Section 3C, Division of Reactor Projects, within the Region I Office of the NRC, and my business ad-dress is USNRC Region I, 031 Park Avenue, King of Prussia, PA 19406. Q.2 Please briefly describe your educational and professional bachground. A.2 I graduated from the United States Naval Academy in 1965 with a Bachelor of Science Degree in Engineering. I completed ex-tensive nuclear submarine officer training programs and had a broad range of supervisory responsibilities aboard one conven-tional and three nuclear submarines. During this period, I qualified as nuclear submarine Chief Engineer. Since August 1975, I have been an employee of USNRC, Region I. My as-signments have included being principal inspector at various 8608150137 PDR 860812 ADOCK 05000320 PDR
4 times for Yankee Rowe, Maine Yankee, R.E. Ginna, Calvert Cliffs Units 1 and 2, and Three Mile Island Units 1 and 2. I also was Senior Resident Inspector for TF.ll-1 from February 1980 until flay 1980. A copy of my professional gralifications and experience is attached. Q.3 In October,1978, what was your professional position? e A.3 I was then the principal or project reactor inspector assigned to inspect Three Mile Island Units 1 and 2. Q.4 In that capacity, did your work include inspections of the TMI-2 facility? A.4 Yes, in that capacity my work included routine periodic inspec-tions of the TMI-2 facility. Q.5 During October, 1978, did you become aware that GPUN had experienced unidentified leakage exceeding the technical specifi-cation requirements? If so, please explain the circumstances surrounding your becoming aware of that fact. A .5 Yes. On the morning of October 18, 1986, at or about 9:00 a.m., I was conducting a routine inspection of plant operations, including observation of control room activities and review of logs and records of both prior and current operations. Inspec-tion Report Number 50-289/78-32, attached as Exhibit A to this testimony, documenterl that inspection. During that inspection, while either in the shift supervisor's office adjacent to the
o e control room or in the vicinity of the shift foreman's desk in the control room, I overheard two or three plant personnel dis-cussing unidentified reactor coolant system (RCS) leakage ex-ceeding the technical specification (TS) requirements. Although I have no specific direct recollection of the participants in this discussion, I believe they included a reactor operator and two senior reactor operators (shift foreman and shift supervisor). The discussion also may have included the Supervisor of Opera-tions , Mr. James Floyd. In any case, at some point I joined this conversation and I became aware that the results of a re-cent RCS water inventory leakage measurement indicated that unidentified RCS leakage was greater than the technical specifi-cations limit of 1 gpm. (I believe the calculated leakage was about 1.3 gpm or some other value more than 1.0 but less than 1.5 gpm. ) Furthermore, I learned that the calculated unidenti-fled RCS leakage had been 2.6 gpm at 7:35 p.m. on October 16, 1978, and had remained greater than 1 gpm since that time. The RCS leakage test records which indicated that unidentified leakage had exceeded the 1 gpm TS limit either were on a desk in the shift supervisor's office or on the shift ! l foreman's desk. The operators were discussing this matter in my presence, and the test results that contained data of exces-sive unidentified RCS leakage were in clear view. Q.6 What action did you take when you became aware of this matter?
A.6 Upon becoming aware of the unidentified RCS leakage problems, I interrupted the routine operations inspection that I had been conducting to question the shift supervisor and/or the supervi-sor of operations about the leakage test results. I believe that it was at that time that I first learned of the operators' incor-rect interpretations of (1) the applicability of the 1 gpm un-identified RCS leakage limiting condition fcr operation (LCO), (2) the relationship of this LCO to its corresponding surveil-lance requirement, and (3) the actions that should be taken any time the LCO limit is exceeded. I believe that it was also my impression at that time that the licensed operators on shift were in the process of taking this problem to operations department and facility management. Nonetheless, I was concerned about some operators' apparent misunderstanding about fundamental aspects of the technical specifications and the actions that were required to be taken when LCOs are not met, both in the cur-rent instance and under other circumstances. Therefore, I left the control room to discuss these issues with Mr. James Seelinger, Superintendent--Technical Support, and Acting Su-perintendent , Unit 2, in his trailer, which was located outside the TMI-2 protected area. Q.7 Describe your discussion with Mr. Seelinger. A.7 During my discussions with Mr. Seelinger, I soon formed the opinion that previously he had not been aware of the unaccept-able RCS unidentified leahage test results , although he may
O have been informed of this matter shortly before my arrival in his trailer. Shortly after our conversation began, Mr. Floyd entered Mr. Seelinger's office and joined the discussions. I clearly recall Mr. Floyd telling me, in effect, that RCS uniden-tified leakage test results must be calculated to be within ac-ceptable limits (leas than 1 gpm) only once every 72 hours in order to be in Icgal compliance with TS surveillance require-ments. In his view, any number of RCS unidentified leakage measurement test results could be greater than 1 gpm, so long as every 72 hours acceptable leskage results were obtained. I did not attempt to determine whether this was a long-standing view or a hastily-formed justification or excuse that Mr. Floyd had argued to avoid a violation of the TS. However, I in-formed Mr. Floyd that in my view his interpretation was clearly incorrect. I stated that the TS LCO limits must always be met, in accordance with the applicable TS facility operating modes, including the results of RCS leakage measurement tests that are conducted more often than required by the 72-hour TS surveil-lance frequency. In addition to this discussion of TS interpretation, I believe that Mr. Floyd expressed a lack of confidence in the computer-calculated results of RCS unidentified leakage, since other leakage indicators, in particular the amount of routine water additions to the makeup tank , had shown that actual l l leakage was less than the calculated values. In addition , l
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Mr. Floyd or Mr. Seelinger stated that RCS leakage measurements l were considered inaccurate or invalid during the changing or transient plant conditions that occurred as a result of the plant's power ascension test program. I do not recall my res-ponse to or acknowledgement of this matter. Uith respect to the problem at that time of having the recent calculation of RCS unidentified leakage greater than 1 gpm, I was informed that niant operators were attempting to identify any leakage source (s) so as to reduce the unidentified leakage to less than 1 gpm. Further, Mr. Seelinger assured me that the plant would bo operated in accordance with the TS action statements that were applicable to excessive RCS leakage condi-tions. Also, I was informed by Mr. Seelinger that the matter would be referred to the Plant Operations Review Committee (PORC) for their review of this potential reportable occurrence. To the best of my recollection, these discussions in Mr. Seelinger's office lasted about 20 to 30 minutes, after which I resumed my routine operations inspection. Q.8 Did you receive additional information about the unidentified RC.9 leakage? A.8 Yes. Later that day, probably in the early afternoon, I was shown RCS unidentified leakage test results that were accept-able in that they showed leakage of less than 1 gpm. I was informed that some amount of leakage had bcen " identified," so i
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4 that the unidentified leakage was reduced, although I do not now recall whether a leak had been found and stopped or re-duced or whether certain leakage had been found and quantified so that the leakage could be considered " identified." I was also informed that a computer input error had been found and cor-rected, so as to reduce the amount of unidentified leakage, but I do not now recall the specific nature of the input error. I believe it was during the afternoon of the next day, October 19, 1978, that I was informed by Mr. Seelinger that the PORC had met to review the operation of the facility during October 16-18, 1978, with the RCS unidentif1nd leakage in ex-cess of the TS limit and that the PORC had determined this matter to be a reportable occurrence. Mr. Seelinger also showed me a draft copy of the report that was being sent to the NRC Region I office. Q.9 Did you discuss the unidentified RCS leakage matter with other NRC officials? A.9 Yes. Later on October 19, 1978, I believe I discussed these i rmiters during a telephone conversation with either my supervi-sor, Mr. Richard Keimig, or the backup project inspector for TMI-2, Mr. William Lazarus. On October 20, 1978, I believe Mr. Lazarus, in my absence, prepared an input to the Inspec-tion and Enforcement (IE) daily report regarding the TS viola-j tion of RCS unidentified leakage requirements. I believe that
on the same day, October 20, 1978, Mr. Lazarus also reviewed the licensee's prompt (24-hour) report of the occurrence (See Exhibit B - Action Control Form dated 10/20/78, and Exhibit C - J. L. Seelinger letter to Boyce H. Grier dated 10/19/78). Q.10 In your judgment, did the licensee violate applicable RCS leak-age TS limits? A.10 Yes. Operation of the facility while exceeding applicable RCS leakage limits was a clear violation of TS requirements. Howev-cr, this occurrence was identified by the licensee and was re-viewed by the PORC; RCS leakage was reduced to acceptable limits within the time frama allowed by the TS after discovery, and the matter was properly reported to the NRC. Q.11 Did licensee inform you that they were following a practice of rounding off test results? A.11 I believe that during my discussions with Pir. Seelinger and fir Floyd, I inquired as to their understanding of the basis for, and the degree of, accuracy associated with the TS LCO for unidentified RCS leakage. The specified limit was written as 1 gpm, as compared with the more specific notation 1.0 gpm. I was curious about the technical basis for this limit as well as any instrument inaccuracies associated with the calculated leak-age measurements. I do not recall any specific responses to my inquiries. Ilowever, my questioning may have led to the prac-tice of "round-off" of RCS unidentified leakage test results, as
described in an operations department memorandum dated October 20, 1978. Although I did not approve the round-off practice, or intend by my inquiries to imply that round-off might be acceptable, I was indeed aware of the implementation of the round-off of test data because I reviewed the operations memo during the inspection, which is documented in Inspection Report 50-320/78-32 (See Exhibit A). During the week following the inspection, I made one or more telephone calls to an HRC person or persons in the Office of liuclear Reactor Regulation to determine the acceptability of "round-off. " I was informed that round-off of test data wan not an allowable practice, and I conveyed this information by telephone to t<tr. Seelinger, who stated that the round-off prac-tice would be terminated. O .12 What other inspections or reviews did you conduct regarding this problem or the results of other unidentified leakage measurements? A .12 During an inspection in December 1978 (See Exhibit D-IR 50-310/78-36), I reviewed records of RCS leakage measurements completed during October 1 - December 11, 1978. Test results which I reviewed indicated that RCS leakage was acceptable. During an inspection in January 1979 (See Exhibit E - IR 50-320/79-01), based on a previous in-office licensee event
report review. I conducted onsite follow-up of licensee event report LER 78-62/1T, dated October 19,1978 (See Exhibit F), which regarded creeeding the TS limit for RCS unidentified leakage without shutdown of the unit . At that time , I believed that the correction actions proposed by the licensee, if adequately implemented , would have been sufficient to preclude recurrence of the problem as I understood it. Subsequently, in April or May 1980, in support of an NRC investigation of alleged RCS leakage measurement falsifica-tion by TMI-2 operators, I reviewed actions taken by the PORC and facility management concerning previous excessive RCS leakage (See Exhibit G with enclosures) . The PORC review and licensec management reporting of the excessive RCS leakage was performed as required by the TSs.
i-i PROFESSIONAL QUALIFICATIONS 4 of DONALD R. HAVERKAMP 3 I graduated from the United States Naval Academy in 1965 with a Bachelor i of Science Degree in Engineering. Following a three-month temporary duty [ assignment with the Submarine Development Group Staff in Groton, Con-
- necticut, I completed the six-month submarine officers training course at Groton, the six-month nuclear power school officer course at Vallejo, Cali-1 fornia, and the six-month DIG prototype qualification program at West Nilton, New York. My additional training included the three-month Polaris
! Missile officer course at the Guided Missile School, Dam Neck, Virginia.
My eight years of military service following the extensive nuclear submarine ' I officer training programs included a broad range of supervisory responsibil-
- ities aboard one conventional and three nuclear submarines. My principal assignments, duties, responsibilities and accomplishments during that period nre summarized below.
May 1967 - October 1900: Asstatant Engineer (8 months) and Supply Offt-ccr (9 months) aboard the conventional submarine USS Pomfret (S S-391) . As Assistant Engineer, responsible for supervision, maintenance, and oper-l ation of all diesel propulsion, electrical and supporting systems. As Supply Officer, responsible for shipboard food service and repair parts manage-i ment. Supervised 1 officer and 19 enlisted personnel. Completed one ex-tended deployment and one regular shipyard overhaul. Qualified in Submarines, i i February 1969 - October 1971: Assistant Weapons Officer (17 months) and Weapons Officer (15 months) aboard the nuclear Polaris submarine USS Ma-than IIale (SSDN 623 (Blue)). Responsible for supervision, maintenance, and operation of missile and torpedo fire control, launching and supporting mechanical, electrical and electronic systems. Supervised two officer and 37 enlisted personnel. Completed final phase of shipyard overhaul, post over-l haul shakedown trials and four deterrent patrolc. Received fleritorious Unit Commendation Medal. Completed Basic Engineering Qualification (sys-tems) portion of Engineering Officer of the Watch (EOOW) watch station. October 1971 - November 1973: Main Propulalon Assistant 9nd Acting Engi- ! neer Officer (3 months) aboard the nuclear attack submarine USS Flasher j (SSN 613). Responsible for supervision, maintenance, and operation of me-i chanical reactor plant and engine room systems, including reactor fluid pri-i mary systems, main engines, turbine generators and associated secondary i systems. Supervised ::1 enlisted personnel. Completed two extended de-2 ployments. Received Navy Achievement Medal. Qualifted as Engineering Officer of the watch and as nuclear submarine Chief Engineer. I t
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February 1974 - June 1975: Navigator / Operations Officer aboard the nucle-ar attack submarine USS Billfish (SSN 676). Responsible for supervision, maintenance, and operation of inertial, celestial and radio electronic naviga-tion systems. Supervised 1 officer and 16 enlisted personnel. Coordinated departmental and shipboard training, including nuclear operator training, while in operation and overhaul status. Planned and conducted several ex-tensive developments. Since August 1975, I have been an employee of the United States Nuclear Regulatory Commission, Region I. Prior to the TMI-2 Accident, I was the principal (project) reactor inspector assigned to inspect reactors in opera-tion, including Yankee Rowe, Maine Yankee, and R.E. Ginna (concurrent-ly), Calvert Cliffs Units 1 and 2, and Three Mile Island Unita 1 and 2. Following the TM1-2 Accident, I was initially involved with the Region I in-cident response activities at the regional office. From March 20,1979 until January 31, 1980, I was assigned to perform various functions primarily at the Tf!I site. Illy initial duties were TMI-2 shift surveillance inspection; liaison support for NRC Commissioners, Congressmen, investigating groups and commissions, and foreign representatives; providing testimony for in-vestigations; and, TMI-2 reactive site inspection. From February 1,1980 until May 29, 1982, I was assigned as the Senior Resident Inspector for TMl-1. From f'ay 30, 1982, until June 21, 1982, I was assigned as the Reactor Li-censing Engineer, Division of heactor Projects, Region I. Since that time, I have been assigned as Project Engineer, Reactor Projects Section 3C, Di-vision of Reactor Projects, Region I.
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Exhibit A ( 8 NOV 1978 i Docket No. 50-320 Metropolitan Edison Company , ATTN: Mr. J. G. Herbein . Vice President - Generation - P. O. Box 542 Reading Pennsylvania 19603 l ! Gentlemen: g ,
Subject:
Inspection 50-320/78-32 This refers to the inspection conducted by Mr. D. Haverkamp of this office on October 16-20, 1978, at Three Mile Island Nuclear Station. Unit 2. Middletown Pennsylvania, of activities authorized by NRC 1.icense No. DPR-73 and to the discussions of our findings held by Mr. Haverkamp with Mr. J. Seelinger of your staff at the conclusion of the inspection. Areas examined during this inspection are described in the Office of i Inspection and Enforcement Inspection Report which is enclosed with this ,
- letter. Within these areas, the inspection consisted of selective
,, , examinations of precedures and representative records, interviews with
- personnel, and observations by the inspector.
Based on the results of this inspection. it appears that one of your activities was not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A. This item of noncompliance has been categorized into the levels as i described in our correspondence to you dated December 31, 1974. This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice." Part 2. Title 10. Code of Federal Regulations. Although Section 2.201 requires you to submit to this office, within 20 days of your receipt of this notice, a written statement of explanation, we note that this item of noncompliance was corrected prior to the com-pletion of our inspection, and therefore, no response with respect to this matter is required.
' In acconiance with Section 2.790 of the NRC's " Rules of Pmetice." Part
- 2. Title 10. Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the NRC's Public Document Room. If this
; report contains any information that you (or your contractor) believe to l
omee >
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- suanawe > _...av r amp /mc Keimig Brunner. - . - .. - - - _ - . - - - - - - -
cave > l_1/ 2/ 7_8, , . , _ p[f[.........7f_ ......... \ . . . . . . __ _ _____..... . . . _ . . . . . . . . ._ . . _ - - . . _ _ _
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i : Metropolitan Edison Company 2 8 NOV '978 be proprietary, it is necessary that you make a written application j within 20 days to this office to withhold such infonnation from public disclosure. Any such application must be accompanied by an affidavit executed by the owner of the information, which identifies the document or part sought to be withheld, and which contains a statement of reasors . which addresses with specificity the items which will be considered by . theCommissionaslistedinsubparagraph(b)(4)ofSection2.790. The. ' information sought to be withheld shall be incorporated as far as possible
- into a separate part of the affidavit. If we do not hear from you in '
this regard within the specified period, the report will be placed in the Public Document Room. No reply to this letter is required; however, if you should have any ' questions concerning this inspection, we will be pleased to discuss them with you. Sincerely, Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch n,y w
Enclosures:
- 1. Appendix A, Notice of Violation
- 2. Office of Inspection and Enforcement Inspection Report Number 50-320/78-32
! cc w/encis: i T. Broughton, Safety & Licensing Manager J. J. Barton, Project Manager R. C. Arnold, Vit.e President - Generation i L. L. Lawyer, Manager - Generation Operations - Nuclear l G. P. Miller, Superintendent J. L Seelinger, Unit 2 Superintendent - Technical Support l I. R. Finfrock, Jr. i Mr. R. Conrad G. F. Trowbridge, Esquire Miss Mary V. Southard, Chairman, Citizens for a Safe Environment (WithoutReport) l l l ~ Ovr,Cu > .............. ~ .. ................... . . . . . . . . ~ . - ~ . . . - ~ . - ~ ~ ~ ~ . ~.~..-~~~~-
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OAtt > ................... .................. ......~...~..... ~ . . ~ . - ~ . - ~ "~""""*-** ""*"**"**" NRC FOHM 318 16 77) i U. S. GOVf HNME N T PRIN TING OF F ICE 1977-237-025 1
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Metropolitan Edison Company 3 15 IICV 1978 t i bec w/encls: IE Mail & Files (For Appropriate Distribution) Central Files PublicDocumentRoom(PDR)(1.PDR) local Public Document Room . Nuclear Safety Infctmation Center (fiSIC) ~ Technical Information Center (TIC) ' REG:I Reading Room j RegionDirectors(III.IV)(ReportOnly) Commonwealth of Pennsylvania Miss Mary V. Southard. Chairman. Citizens for a Safe Environment , n.m
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sununur > ................... .........~......... ................... .................. ................ - ..... ..... ..- 0 ATE > ................... .................. ................... .... .............. .................. ................ NXC FOMM 318 to F M - W U. S. GOVE RNME NT PRINTING OF F ICE 1977 737 02S
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APPENDIX A NOTICE OF VIOLATION Metropolitan Edison Company Docket No. 50-320 Based on the results of an NRC inspection conducted on October 16-20 .,. 1978, it appears that one of your activities was not conducted in full ' compliance with conditions of your NRC Facility License No. DPR-73 as - indicated below. This item is a Deficiency. Technical Specification 6.8.1.a states:
" Written procedures shall be established, implemented and main- '
tained covering the activities referenced below:
- a. The applicable procedures reconnended in Appendix "A" of ,
Regulatory Guide 1.33, Noveaber,1972." Regulatory Guide 1.33, November,1972 states, in part:
"The following are typical safety-related activities which should be covered by w,*itten procedures . . .
A. Administrative Procedures y
- 10. Bypass of Safety Functions and Jumper Control."
TMI Station Administrative Procedure 1013. " Bypass of Safety Functions and Jernper Control." Revision 7, states, in part: (1)
. . . no junper shall be installed until it has bevn identi-fled by tags . . . placed upon the jumper at each end . . . .
All jumper tags shall be RED in color . . . . " (ii) "
. . . Whenever the (lifted) leads are replaced the following infonnation shall be filled in the log: Date, Time, Replaced By . . . ."
(iii) "
. . . When a . . . jumper . . . is in effect greater than 12 months, it should be evaluated by the cognizant engineer for the affected system . . . . The evaluation should document the reasons why the wiring change has not been made permanent (orremoved)andwhatfinaldispositionofthesituationis intended . . . ."
l { OF F tCE > ................... ................as<.................. ................... .................. ............... M If , s. SURNAMt> ................... ................... ....II.............. ................... .................. ...........'.... DATED '................... ,,,,,,,,,,,,,,,,,, .................. ,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,, N%C P OMM 318 (6-77) W U. S. Govt HNMF.N T PRIN T4NO OF FICL 1977-737-025 --
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t 1 APPENDIX A 2
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Contrary to the above. the following examples of nonconformance were found
. on October 18, 1978:
1 (i) Jumper #27 was identified by one BLtlE (lifted lead) tag. I (ii) Lifted leads #2, #3 and r20 were replaced and the respective ~ l log sheets were not filled in with applicable information. , (iii) Jumper #3 has been in effect since July 22, 1977, a period j of 15 months, and no evaluation has been perfonaed. I t I t '1%'$'9 i t i 1 I i l OF PICt > ................... *** ..****.**=***a-*** ************* ******************* ****************** ******a******** L ............... 5UMNAMt> ................... .................. ..................................... .................. 6 DATED ................... ,.................. .................. ................... .............*.... .*.......**.... Nnc e OMM Jte (6 77) W U. S. GOve HNMtt47 PHIN TING Of P ICL 1977 231-025
. - ( ) u.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSFECTION AND ENFORCEMENT Region I Report No. 50-320/78-32 Docket No. 50-320 License No. DPR-73 Priority -- Category 82 Licensee: Metropolitan Edison Comoany P. O. Box 542 Readino Pennsylvania 19603 Facility Name: Three Mile Island Nuclear Station, Unit 2 Inspection at: Middletown, Pennsylvmia Inspection conduct : October 16-20, 1978 / Inspectors: / //< # fr # ' /' '
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date signed D. R erk@,Reactordnspector date signed date signed Approved by- ^^"# //"7 ctor Projects date signed
. R. K , Chief Sectio .1 R0 Dranch Inspection Summary:
Inspection on October 16-20, 1978 (Report No. 50-320/78-32? Areas Inspected: Routine, unannounced inspection by a reg'onal based inspector of startup test results; power level plateau data; plant operations including shift logs and records and facility tour; licensee followup actions concerning selected previous inspection findings; licensee events; IE Circulars; and, selected licensee periodic reports. The inspection involved 32 inspector-hours onsite by one NRC regional based inspector. Results: Of the eight areas inspected, one item of noncompliance was found in one area (Deficiency - failure to comply with administrative controls for jumpers and lif ted leads, Paragraph 5.a). l Region ! Form 12 (Rev. April 77) 1 I
s I DETAILS
- 1. Persons Contacted Metropolitan Edison Company Mr. C. Adams, Unit 2 shift Foreman
*Mr. M. Bezilla, Unit 2 PORC Secretary
*Mr. J. Floyd, Unit 2 Supervisor of Operations Mr. B. Mehler, Shift Supervisor Mr. T. Mulleavy, Radiation Protection Supervisor Mr. F. Scheimann, Jr., Unit 2 Shift Foreman
*Mr. J. Seelinger, Unit 2 Superintendent - Technical Support Mr. A. Stowe, Record Retention Administrator Mr. R. Warren, Unit 2 Lead Mechanical Engineer Mr. W. Zewe, Shif t Supervisor General Public Utilities Service Corporation Mr. C. Gatto, Lead Mechanical Test Engineer Mr. R. Toole Test Superintendent Babcock and Wilcox Mr. J. Flint, Startup Test Engineer The inspector also interviewed several other licensee employees during the inspection. They included control room operators, technical and engineering staff personnel and general office personnel.
- denotes those present at the exit interview on October 20, 1978
- 2. Licensee Action on Previous Inspection Findinas (Closed)Unresolveditem(320/78-10-04): QA Record Index. An index of quality assurance records has been issued for Unit 2 per the requirements of Generation Procedure GP-0063, Change Memo #4, and ANSI N45.2.9. Information contained in the index includes record type, retention periods, storage location and ret.ponsible organiza-tion. The ir.spector had no further questions concerning this item.
s k I 3 (Closed)UnresolvedItem(320/78-18-01): Turnover of test program records. TMI Station Superintendent letter to GPUSC, dated June 1, 1978, designates the authorized recipient of records which are being turned over to MEC from the construction project. Acceptable arrangements have been made for interim storage of the test program related records until permanent facilities are available. The inspector had no further questions concerning this item. (Closed)Norcompliance(320/78-26-01): Failure to update emergency procedures. The licensee's corrective measums have been completed, as described in MEC letter to NRC: Region I, Serial GQL 1481, dated September 6, 1978. The Controlled Procedures Distribution List nas been revised to include appropriate distribution of changes and revisions to HPP 1670.6 and HPP 1670.12 for the emergency monitoring kits. Recently completed quarterly surveillance of these kits, per HPP 1778, included verification that the information book in each kit had up-to-date procedures. The inspector had no further questions concerning this item.
- 3. Startup Test Results Evaluation The inspector conducted an evaluation of the following startup tests.
-- TP 800/11 (MTX 147.21), Core Power Distribution (15% and 40%
power level plateau testing completed on September 19 and October 7,1978)
-- TP 800/32 (MTX 147.33), Loss of Off-Site Power (15% power level plateau results approved by TWG on May 19,1978)
-- TP 800/31 (MTX 147.32), Pseudo Dropped Rod (40% power level plateautestingcompletedonOctober4,1978)
The test records were evaluated to verify the following items.
-- Test changes had been approved in accordance with administrative procedures, properly entered into the procedure, accomplished if actions were necessary, and did not change the basic objective of the test.
-- Test deficiencies had been resolved, accepted by appropriate nanagement, retest conducted if required, and any system or process changes necessitated have been properly documented and reviewed.
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-- Test summaries and evaluations had been performed by the cognizant engineers, and test results had been compared with established acceptance criteria. -- "As-run" copies of the test procedures contain completed data sheets (sample), data are recorded where required and are within acceptance tolerances (sample), test deficiencies noted receive appropriate review and evaluation, and individual test '
steps and data sheets have been properly initialed and dated.
-- Quality Assurance inspection records have been completed to document the adequacy of the test package contents, to indi-cate independent review of test records and data package contents, and an independent audit was performed during test performance, as required by administrative procedures. -- Approval of the test results by those personnel charged with responsibility for review and acceptance has been documented, and if the off site review consnittee has audited the test package, that their comments are included and corrective action has been taken if required.
The inspector used one or more of the following acceptance criteria for the above items.
-- Final Safety Analysis Report
-- Technical Specifications
-- Test Instruction 7 GpU Startup Problem Report
-- Test Instruction 9. Conduct of Test
-- Test Instruction 13 Test Interface Instructions
-- Test Instruction 18. Test Procedure Documents
-- Regulatory Guides
-- Inspector Judgment
-- Quality Assurance Program
5 Findings were acceptable, except as noted below.
-- During performance of TP 800/31, the runback rate did not meet the acceptance criteria. This item is unresolved acceptable retest at the 75% power level plateau (pending an 320/78 01).
-- TP 800/11 and TP 800/31 have been approved by TWG as acceptable for proceding to the 75% power level plateau, but have not yet received final approval. This itefr is unresolved pending final T'<!G approval of these TPs (320/78-32-02). .
- 4. Power Level Plateau Data Review
- a. Verification of Licensee Evaluaticn of Test Results The inspector conducted a review of the following startup tests.
-- TP 800/5 (MTX 147.19), Reactivity Coefficient at Power (40%
1978) power level plateau testing completed on October 2,
-- TP 800/35 (MTX 147.36), Effluent and Effluent Monitnring System Test (15% and 40% power level plateau testing completed on April 23 and September 29,1978)
-- TP 800/18 (MTX 147.27), Power Imbalance Detector Cor-relationTest(40%
on October 7,1978) power level plateau testing completed
-- TP800/36(MTX147.37),ShutdownfromOutsidetheControl 4 Room (15% power level plateau testing completed on September 19,1978)
-- SP800/8(MTX91.4),ICSTuningatPower(15%and40%
power level plateau testing completed on September 20 and October 5,1978)
-- TP 800/23 (MTX 147.31), Unit Load Transient Test (40%
power level plateau testing completed on October 17, 1978)
-- TP800/2(MTX108.7),NuclearInstrumentCalibrationat 1
Power (15% and 40% power level plateau testing completed on September 18 and October 1,1978) l l i
i 6 s
- -- TP800/12(MTX147.22),UnitLoadSteadyStateTest(15%
and 40% power leval plateau testing completed on September 19 and September 30, 1978)
-- TP800/22(MTX147.30),NSSHeatBalance(15%and40%
power level plateau testing completed on September 18 and September 29, 1978) The test records were reviewed to verify the following items.
-- Test summaries and evaluations had been performed by the cognizant engineers, and test results had been compared with established acceptance criteria.
-- Approval of the test results by those personnel charged with responsibility for review and acceptance has been documented, and if the off site committee has audited the test package, that their comments are included and corrective action has been taken if required.
The inspector used one or more of the following acceptance criteria for the above items.
-- Final Safety Analysis Report
-- Technical Specifications Test Instruction 18. Test Procedure Documents
-- Regulatory Guides
-- Inspector Judgment
-- Quality Assurance Program Findings were acceptable, except as noted below.
-- TP 800/33, Pseudo Rod Ejection Test was not perforred.
i Deletion of this test from the power escalation testing program was approved by NRR letter to MEC, dated June 12, 1978.
-- All of the above tests have been approved by TWG as ac-ceptable for proceeding to the 75% power level plateau, but the test results have not yet received final approval.
This item is unresolved pending final TWG approval of the testresults(320/78-32-03).
._n.- . , . _ . , , , . . _ - - . , , ,
4 i 7
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- b. Authorization to Raise Power The inspector reviewed the licensee's evaluation of the 15%
and 40% plateau test results and the authorization for pro-ceeding to the next test plateau. This review included dis-cussions with licensee and startup group representatives, observation of PORC Meeting No. 290 on October 17,1978,and review of the following items.
-- Startup tests listed in Paragraphs 3 and 4.a
-- SP 800/21 (MTX 147.29), Unit Startup and Power Escalation Test (TWG approval received to escalate power to 40% and 75% on September 20, 1978 and October 17,1978)
-- Minutes of PORC Meetings Nos. 268, 28C and 290 The review was conducted to assure or confirm the following items.
-- All applicable testing has been completed.
-- All testing anomalies have been evaluated and resolved by the licensee.
-- The licensee has reviewed Technical Specification require-ments applicable to the next higher power level and has fully implemented them.
-- The licensee performed core and plant surveys to assure safe operation during the increase of power level and arrival at the next plateau; including examination of flux distribution, core performance, reactor heat balance, unexpected radioactivity and radiation leakage, pressure boundary leakage, and reactor coolant chemistry.
-- The licensee has extrapolated the results of tests to applicable plateaus in the power ascension program, has compared the extrapolation with predicted plant performance, and has determined that it is reasonable and prudent to continue the testing program to the next planned power level plateau. ,
.__- . . , _ - . _ - - ~_. -- . . -- _ _ _ . _ _ _ . _ _ _ . _ - - . - . - -
I i 9 8 The inspector used one or more of the following acceptance criteria for the above items.
-- Final Safety Analysis Report
-- Technical Specifications
-- Test Instruction 9 Conduct of Test
-- Regulatory Guides
-- Inspector Judgment Findings were acceptable.
- 5. Review of Plant Operations
- a. Shift Logs and Operatina Records The inspector reviewed the following logs and records.
-- Shift Foreman Log, Control Room Log Book, Control Room Operator's Log Sheets, Primary Auxiliary Operator's Log-Tour Readings, Primary Auxiliary Operator's Log-Liquid Waste Disposal Panels, Secondary Auxiliary Operator's Log Sheets, and Auxiliary Operator Log Sheets-Out-Building Tour, dated August 1 - October 15, 1978
-- Shift and Daily Checks, dated July 26 - October 15,1978
-- Jumper, Lifted Lead, and Mechanical Modifications Log (active and cleared); entries made during August 1 -
October 15, 1978, and selected active entries
-- Fire System Removal from Service Notification Log; entries made during August 1 - October 15, 1978
-- Applications for Apparatus to be Taken Out of Service; those active on October 20,1978, and those cleared, dated October 1-19,1978
-- Do Not Operate and Caution Tag Logi entries made during August 1 - October 15, 1978
1 9
-- Transient Cycle Log Book; entries made during August 1 -
October 15, 1978
-- Unit 2 Operations Department Memos 2-78-16 through 2-78-20 The logs and records were reviewed to verify the following items.
-- Logkeeping practices and log book reviews are conducted in accordance with established administrative controls.
-- Log entries involving abnormal conditions are sufficiently detailed.
-- Operating orders do not conflict with Technical Specifications (TSs).
-- Jumper Log and tagging log entries do not conflict with TSs.
-- Jumper / lifted lead / mechanical modification and tagging opera-tions are conducted in conformance with established admini-strative controls.
-- Problem identification reports confirm compliance with TS reporting and LC0 requirements.
Acceptance criteria for the above review included inspector judgment and requirements of applicable Technical Specifications and the following procedures.
-- Station Administrative Procedure (SAP) 1002, " Rules for the Protection of Employees Working on Electrical and Mechanical Apparatus " Revision 13
-- SAP 1010. " Technical Specification Surveillance Program "
Revision 12. TCN 2-78-624
-- SAP 1011. " Controlled Key Locker Control," Revision 16
-- SAP 1012. " Shift Relief and Log Entries," Revision 8
-- SAP 1013. " Bypass of Safety Functions and Jumper Control."
Revision 7
I 1 . l l 10
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-- SAP 1016 " Operations Surveillance Program," Revision 12
-- SAP 1033, " Operating Memos and Standing Orders," Original s
-- SAP 1037, " Control of Caution and DNO Tags," Revision 1 Findings were acceptable, except as noted below.
-- SAP 1013 includes the following requirements for administra-tive control of jumpers and lifted leads.
(1) No jumper shall be installed until it has been identi-fied by tags placed upon the jumper at each end. All jumper tags shall be RED in color. (2) Whenever lifted leads are replaced, the following information shall be filled in the Lifted Leads Log Sheet: date, time, replaced by. (3) When a jumper is in effect greater than 12 months, it should be evaluated by the cognizant engineer for the affected system. The evaluation should document the reasons why the wiring change has not been made permanent (or removed) and what final disposition of the situation is intended. The inspector observed the following discrepancies on October 18, 1978. (1) Jumper #27, at ICS Terminal Board 10-5, was identified by one BLUE (lifted lead) tag vice two RED jumper tags. (2) Lif ted leads #2 and #3, at Terminal Board 1TS, and lif ted lead #20, at ICS Cabinet Terminal Board 8-1, were re-placed and the respective log sheets were not filled in with applicable infonnation. (3) Jumper #3, at the Hydrogen Seal Oil Cabinet 307, has been in effect since July 22, 1977, a period of 15 months, and no evaluation of the jumper has been made by the cognizant engineer.
11 The inspector stated that failure to confonn with require-ments of SAP 1013 was considered an item of noncompliance at the Deficiency level of severity. Prior to the end of the inspection, the specific discrepancies were corrected and evaluations were in-progress. In addition, a licensee audit of all jumpers and lifted leads was performed to as-sure that SAD 1013 implementation and log sheet status was correct. Licensee representatives stated that SAP 1013 would be reviewed and revised, if more stringent controls including periodic licensee audits were deemed necessary. The inspector stated that no response was required to the item of noncompliance and that the licensee's audit results and the need for additional corrective actions will be re-viewed during a subsequent inspecticn (320/78-32-04).
-- SAP 1013 contains administrative controls for temporary mechanical modifications, including installation or re-moval of blank flanges and use of spool pieces or temporary lines that are not a design part of the respective system.
The inspector noted that SAP 1013 includes no specific controls for installation of gagging devices on safety or relief valves that are not a design part of the system. This item is unresolved pending licensee review of the need to include controls for gagging devices in SAP 1013 (320/78-32-05).
- b. Plant Tour At various times on October 18-20, 1978, the inspector conducted tours of the following accessible plant areas.
-- Auxiliary Building l
' -- Turbine Building l l
-- Fuel Handling Building
-- Control.and Service Building
-- Control Room
-- Circulating Water Pump House l
-- Switchgear Rooms
-- Inverter and Battery Rooms
-- Makeup Pump Rooms
-- West Cooling Tower
12
- The following observations / discussions / determinations were made.
-- Control Room and local monitoring instrumentation for various components and parameters was observed.
-- Radiation controls established by the licensee, including the posting of radiation and high radiation areas, the condition of step-off pads, and the disposal of protective clothing, were observed. Radiation Work Permits used for entry to radiation and controlled areas were reviewed.
Plant housekeeping, including general cleanliness conditions and storage of materials and components to prevent safety and fire hazards, was observed.
-- Systems and equipment in all areas toured were observed for the existence of fluid leaks and abnormal piping vibrations.
l
-- Selected piping snubbers / restraints were observed fo.'
I proper fluid level and condition / proper hanger settings.
-- The indicated positions of electrical power supply breakers and selected control board equipment start switches and remote-operated valves and the actual positions of selected manual-operated valves were observed.
-- Selected equipment lockout tags, caution tags, and Do-Not-Operate tags were observed for proper posting and the tagged equipment was observed for proper positioning, l where applicable.
-- Selected jumper and lifted lead markers were observed for proper identification and the effected wiring changes l
were observed for proper completion. The Control Board was observed for annunciators that nor-mally should not be lighted during the existing plant conditions. The reasons for the annunciators were discussed with control room operators.
-- The licensee's policy and practice regarding plant tours was reviewed.
-- Control Room manning was observed on several occasions during the inspection.
13 Acceptance criteria for the above items included inspector judgment and requirements of 10 CFR 50.54(k), Regulatory Guide 1.114, applicable Technical Specifications, and the following procedures.
-- SAP 1002, " Rules for the Protection of Employees Working on Electrical and Mechanical Apparatus," Revision 13
-- SAP 1003, " Radiation Protection Manual," Revision 12
-- SAP 1008, " Good Housekeeping," Revision 4
-- SAP 1009, " Station Organization and Chain of Command,"
Revision 3
-- SAP 1028, " Operator at the Controls," Original SAP 1037, " Control of Caution and DN0 Tags," Revision 1
-- SAP 1034, " Control of Combustible Materials," Original The inspector findings were acceptable, except as noted below.
-- Several discrepancies concerning the identification and control of jumpers and lifted leads were observed, as described in Paragraph'5.a.
-- Plant housekeeping conditions have improved since previous inspections.
- 6. In-Office Review of Licensee Event Reports (LERs)
The LERs listed below were reviewed in the Region I office promptly following receipt to verify that details of the event were clearly reported including the accuracy of the cescription of cause and the adequacy of corrective action. The LERs iere also reviewed to deter-mine whether further information we., required from the licensee, whether generic implications were involved, whether the event should be classified as an Abnormal Occurrence, and whether the event war-ranted onsite followup. The following LERs were reviewed.
*-- LER 78-50/lT, dated August 28,1978 (Excessive R.B. personnel airlock leakage, due to 1/4" hole drilled through airlock bulk-head during installation of supports for electrical tabling)
- denotes those LERs for onsite followup
14
*-- LER 78-51/1T, dated September 6,1978, and Update LER 78-51/1T, dated September 19,1978 (Certain safety-related valves did not have cable splices installed per the FSAR, due to being overlooked by the A/E at the time splicing modifications were being performed)
*-- LER 78-52/1T, dated September 11,1978 (Main steam lines were determined to be incapable of withstanding a turbine trip from 100% power, due to undersized installed restraints which could not suppress faster closure (50 msec) of turbine stop valves than originally specified (150 msec))
-- LER 78-53/3L, dated September 25, 1978 (Safety injection channel "C" did not trip during cooldown at the required RCS pressure setpoint, due to instrument bi-stable failure)
*-- LER 78-54/3L, dated September 27, 1978 valve to miscellaneous waste holdup (R. B. sump) tank (WDL-V271 pump was not discharge supplied with containment grade limit switches, torque switch and motor, due to a purchasing error by the A/E)
-- LER 78-55/3L, dated October 5,1978 (Control room emergency air handling system damper 4092C failed to close during sur-ve111ance testing, due to improper orientation of certain instrument air tubing components)
-- LER 78-56/3L, dated October 16,1978 (Inoperable absolute position indicator for control rod 6-11, due to improperly operating reed switch)
-- LER 78-57/3L, dated September 29, 1978 (Remote shutdown display instrumentation was inoperable in Mode 3, due to inadvertent grounding of the patch panel power supply during maintenance work)
-- LER78-58/3L,datedOctober4,1978(Containmentisolation valve WDL-V1125 failed to close on manual initiation test signal, believed to be due to a dirty control relay contact)
*-- LER 78-59/3L, dated October 2,1978 (Bolted motor lead connections on containment isolation valves MU-V2A/B were not taped per environmentally qualified methods, due to a personnel error duringconstruction)
- denotes those LERs selected for onsite followup
i 15
**-- NPDES Permit 0009920 Update Noncompliance Notifications 78-05 througli 78-07
'. **-- NPDES Permit 0009920 Noncompliance Notifications 78-08 through 78-15
**-- NPDES Permit 00099201 Noncompliance Notifications 78-16 through 78-21 The above LERs were closed based on satisfactory review in the Region I office, except those LERs selected for onsite followup.
- 7. Onsite Licensee Event Followup For those LERs selected for onsite followup (denoted in Paragraph 6), the inspector verified that the reporting re Technical Specifications and GP 4703 (Original) quirements had been met, that of appropriate corrective action had been taken, that the event was reviewed by the licensee as required by Technical Specifications,
- and that continued operation of the facility was conducted in conformance with Technical Specification limits.
The inspector's findings reaarding these licensee events were acceptable, unless otherwise :1oted below.
-- LER 78-54/3L described a purchasing error by the unit A/E which resulted in WDL-V271 being supplied with non-containment grade components. The LER stated that all other safety-related, motor-operated valves inside containment were being inspected for similar errors. This corrective action is being tracked by PORC Action Item #2-78-051, which is scheduled for completion by October 31, 1978. Licensee closecut of PAI #2-78-051 will be reviewed during a subsequent inspection.
- 8. IE Circular Followup The inspector reviewed the licensee's followup actions regarding the IE Circulars listed below.
l -- IEC 78-06, " Potential Common Mode Flooding of ECCS Equipment Rooms at BWR Facilities," dated May 31,1978
-- IEC 78-13, "Inoperability of Multiple Service Water Pumps,"
dated July 10, 1978 i
-- IEC 78-15. " Tilting Disk Check Valves Fail to Close with Gravity in Vertical Position," dated July 24, 1978 IEC 78-16, "Limitorque Valve Actuators," dated July 26, 1978 l
** denotes those environmental reports subject to generic and selective l onsite followup during a subsequent environmental inspection l
l
16 This review included discussions with licensee personnel, review
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of selected facility records, and observation of selected facility equipment and components. With respect to the above Circulars, the inspector verified that the circular was received by appropriate licensee management, a review for applicability was perfonned, and that action taken or planned is appropriate. Acceptance criteria for the above review included inspector judgment and roquirements of applicable Technical Specifications and facility procedures . i.icensee followup to the above Circulars was acceptable, unless otherwise noted below.
-- PORC review of IE Circular 78-06 is being tracked by PORC Action Item (PAI) #2-78-033, rescheduled for completion by November 1, 1978. Field Questionnaire #2617 was submitted to Burns and Roe to obtain information on the design of the decay heat and building spray vaults, for which no water-tight coverings are provided. In the event of a major pipe break on nuclear services river water piping, these vaults might be subject to simultaneous flooding. This item is unresolved pending completion of PORC review of PAI #2-78-033 (320/78-32-08).
-- PORC review of IE Circular 78-13 was documented and closed by PAI #2-78-047. PORC determined that TMI Unit 2 has adequate approved operating and surveillance procedures to mitigate the problems of surface ice, low river water level and silting, as described in IEC 78-13.
-- PORC review of IE Circular 78-15 was documented and closed by PAI #2-78-044. All tilting disk type containment isolation check valves and check valves under ISI scope were installed in a horizontal piping run, except NS-VllA-C. The valve vendor informed the licensee that the tilting disk check valves sup-plied should be installed in a horizontal piping run for maximum operational reliability, however, the valves should ,
function properly in a vertical piping run. Valves NS-VilA-C have been satisfactorily tested on a quarterly basis per SP 2303-M30. No piping modifications were considered necessary.
I 1 17 I PORC review of IE Circular 78-16 was documented and closed i by PAI #2-78-045. Four SBM-3 and four SMB-2 Limitorque valve actuators with 3600 rpm motors are used in engineered safety systems at TMI Unit 2. The valves are only opera-ted manually during a loss of power, when placing the valve on its backseat for a packing adjustment, or for a limit switch adjustment. Thus, the potential for failure of the actuators, resulting from manual operation, is minimal. Applicable maintenance and operating procedures require the actuator to be cycled automatically after manual valve operation. Four of the valves are electrically cycled monthly for E. S. System Testing. Two of the valves are locked opened at RCS pressure above 700 psig and are only closed for cold shutdown. The remaining two valves are closed at RCS pressure above 320 psig and are only opened for decay heat removal or for post-LOCA long term cooling. No additional actions for minimizing manual valve operation or procedures for verifying actuator operability were considered necessary.
- 9. In-Office Review of Periodic Reports The periodic reports listed below were reviewed in the Region I office to verify that the report included information required to be reported and that test results and/or supporting information discussed in the t
report were consistent with design predictions and perfonnance speci-l fications, as applicable. The reports were also reviewed to ascertain whether planned corrective action was adequate for resolution of identi-fied problems, where applicable, and to determine whether any information contained in the report should be classified as an Abnormal Occurrence. The following TMIz 2 periodic reports were reviewed.
-- July Operating Report, dated August 11, 1978 August Operating Report, dated September 11, 1978 1 -- September Operating Re ort, dated October 10, 1978 l
The above reports were clostd based on satisfactory review at the Region I office. .
- 10. Unresolved Items !
- Unresol.ved items are matters about which more information is required in ordde to ascerf.ain whether they are acceptable items, items of i .
noncompliance, os deviations. Unresolved items disclosed during this I t inspection are discussed in Paragraphs 3, 4.a. 5.a and 8. l 1
^
18
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- 11. Exit Interview The inspector met with the licensee representatives (denoted in Para-graph 1) at the conclusion of the inspection on October 20, 1978.
The inspector stanmarized the purpose and scope of the inspection and the findings.
'?
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s /4 hA ll-a - 7[ ,.fy to- m . Exhibit'Bt : 1 ACTION CONTROL TORM - .e REPORT OF NONROUTINE EVENTS FACILITY:
< DOCIET NuMan m TIAL REPORT NuMBEa rott0WUP RZr0RT NuMan ro rig ltl,algl/ 7
< o 7 2 o l7 S ' ol4 l2_ o / / 7
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/ EVENT DATE INITIAL REPORT DATE FOLLOWUP REPORT DATE
/ d / T 7 2 / o / 17 % 1/ / 'o / '7 s M M D D Y Y M M- D D T T M M D D Y Y IN OFFICE TIME EIPENDED INSERT REPORT TTPE NUMBER
- 1. Reportable Occurrence 4. Information g d MINUTES 2. Environmental Deviation 5. Overexposure
- 3. Construction Deficiency 6. Other Report -
EVENT TITLE: - 73 f / MJ / r 1 F6 f f GS O Al i D E /V T i F / E th L5 6 r +6 A= EX c.lEG b e l) a v r ;e o u 7 E Mu r D b owN A h 9 @ i!Ei iiiiidgem ib o er a a e r 61 D El + o' A4 r T e M T E Q () AL E Y A Y r c Id e F T E c d I c A L S p C C I C I c. A T-r e b) P G & d t k E M E M Y Z i
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Check here if exempt from PDR Check here if No Additional Report is Expected ack here when Data is encerad into Computer / p: ~.. %WfN.tkH%h :k 4hi?hv.V '. kWE'i +!f.A'
-- 'S ThisreportwasscreenedinaccordInce'withProbedureIfumber 907123 an[ "
Regional Office Instruction 1900. All required actions have been initiated. 6 d //[d
' ^ ~ ~ ~
Pusject Istfpactor C- - REPARES: II:I Form 39 (Revised,) D cember 1976 *
- - - . - - . . , ,-.yw__.-. , . - - - - - - - - - - - - - - - - . ~ - - - - - . . , - _ - _ - - . - . - - - - . - - - - --- - - - - - - - - - - - , - - - - - - - - - - P--
1
, 1 Exhibit C
* / )
Meteopelitan Edison Company PNt Ofika Bom 16')
,g ~ __ P.%f11ttovn. Pe'nsy;vania 17057 i
/1/ 914 5011 j 1
October 19, 1970 Mr. Boyce H. Grier Director of Regulatory Operations Region 1 . Nuclear Regulatory Comission 631 Park Avenue King nf Prussia, PA 19406 Operating License: DPR-73 Docket: 50-320 -
Subject:
Reportable Occurrence No. 73-62/IP j
Dear Mr. Grier:
This telegram is to confinn the conversation between Mr. J.L. Seelinger, Unit 2 Superintendent Technical Support, and Mr. D. Haverkarg. Region I NRC at 1530 hours on October 19, 1978. A situation considered reportable under technical specification 6.9.1.8.b was discovered at 1000 haurs on October 19, 1978, when it was detemined that the limiting condition for operation (LC0), action b, for T.S. 3.4.6.2 was not invoked when surveillance procedure, 2301-301, data obtained at 1935 on 10-16-78 showed an Unidentified leakage greater than 1 gprh (2.6 gem actual unidentified leakage). This event occurred due to personnel errors in interpreting both the LCO and surveillance performance reqwirements of T.S. 3.4.6.2. i l Unidentified leakage was reduced to T.S. limits at 0735 on 10-18-78. Further details and corrective action will be discussed in the followup report. p J.L'..Seelinger Unit 2 Superintendent / Technical Support JLS:bil f/+ fccr:e h!vy Cctr.v:, .,:s /sr r:ye c'we G ra; P.str ; U: , , - 9, vem
Exhibit D l ef %
# \ UNITED STATES l y *; ' NUCLEAR REGULATORY COMMISSION j j REGION I KING OF PRUS$1 A. PENNSYLVANIA 19406 Docket Nos. 50-289 g 50-320 / ME Metropolitan Edison Company ATTN: Mr. J. G. Herbein Vice President - Generation P.O. Box 542 Reading, Pennsylvania 19640 Gentlemen:
Subject:
Combined Inspections 50-289/78-23 and 50-320/78-36 This refers to the inspection conducted by Mr. D. Haverkamp of this office on December 4-8 and 12-14,1978, at Three Mile Island Nuclear Station, Units 1 and 2, Middletown, Pennsylvania, of activities auth-orized by NRC License Nos. OPR-50 and DPR-73 and to the discussions of our findings held by Mr. Haverkamp with Mr. J. Logan and other members of your staff at the conclusion of the inspection, and to a subsequent telephone discussion between Mr. Haverkamp and Mr. G. Kunder of your staff on December 22, 1978. Areas examined curing this inspection are described in the Office of Inspection and Inforcemert Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of selective examinations of procadures and representative records, interviews with personnel, measurements made by the inspector, and observations by the inspector. Based on the results of this inspection, it appears that one of your activities was not conducted in fell compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A. This item of noncompliance has been categorized into the levels as described in our correspondence to you dated December 31, 1974. This notice is sent to you pursuant to the provisions of Section 2.201 of the r NRC's'" Rules of Practice", Part 2 Title 10, Code of Federal Regulations.
- Section 2.201 requires you to submit to this office, within twenty (20) days of your receipt of this notice, a written statement or explanation in reply including: (1)correctivestepswhichhavebeentakenbyyou and the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full com-l pliance will be achieved.
l l l t
Metropolitan Edis- Company , 2 9 JAN 1979 In accordance with Section 2.790 of the NRC's " Rules of Practice", Part 2 Title 10, Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the NRC's Public Document Room. If this report contains any information that you (or your contractor) believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure. Any such application must be accompanied by an affidavit executed by the owner of the information, which identifies the document or part sought to be withheld, and which contains a statement of reasons which addresses with specificity the items which will be considered by the Connission as listed in subparagraph (b)(4) of Section 2.790. The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If wa da ret hear from you in this regard within the specified period, the report will be placed in the Public Document Room. Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely, 4I./(, Eldon J. Brunner, Chief Reac' tor Operations and Nuclear Support Branch
Enclosures:
- 1. Appenc',ix A, Notice of Violation
- 2. Offica of Inspection and Enforcement Combined Inspection Report Numbers 50-289/78-23 and 50-320/78-36 cc w/encls:
E. G. Wallace, Licensing Manager J. J. Barton, Project Manager R. C. Arnold, Vice President, Generation i L. L. Lawyer, Manager, Generation Operations - Nuclear l - G. P. Miller, Superintendent J. L. Seelinger, Unit 1 Superintendent J. B. Logan, Unit 2 Superintendent G. A. Kunder, Unit 2 Superintendent - Technical Support I. R. Finfrock, Jr. Mr. R. Conrad G. F. Trowbridge, Esquire Miss Mary V. Southard, Chainnan, Citizens for a Safe Environment (Without Report)
. . i -
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Metropolitan Edison Company 3 0 # l bec w/encis: IE Mail & Files (For Appropriate Distribution) Central Files Public Document Room (PDR) local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC) Technical Infomation Center (TIC)_ REG:I Reading Room RegionDirectors(III,IV)(Reportonly) Commonwealth of Pennsylvania Miss Mary V. Southard, Chaiman, Citizens for a Safe Environment 1 j l 4 e _,_. . - , . _ _ _ -._. . . .. .._,_x_. _,. . , _ _ ,_ _ ,_.. - -
APPENDIX A NOTICE OF VIOLATION Metropolitan Edison Company Docket No. 50-320 Based on the results of an NRC inspection conducted on December 4-8'and 12-14, 1978, it appears that one of your activities was not conducted in full compliance with conditions of your NRC Facility License No. DPR-73 as indicated Lelow. This item is a Deficiency. Technical Specification 4.6.1.1 states, in part: " Primary CONTAI:'- MENT INTEGRITY shall be demonstrated:
- a. At least once par 31 days by verifying that:
- 1. All penetrations *... are closed by valves...".
*Except valves ... which are located inside containment and are locked, sealed or otherwise secured in the closed position. These penetrations shall be verified closed during each COLD SHUTDOWN except that verification of these penetrations being closed need not be performed more often than once per 92 days.
Contrary to the above, containment penetration isolation valves inside containment were not verified closed during two COLD SHUT-DOWN periods on November 10-20 and 23-30,1978. These valves had not been verified closed since August 26, 1978, during a previous COLD SHUTDOWN period. l l i l l f
L. . NUCLEAR REGULATORY COMMISSIt,.. OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-289/78-23 Report No. En_1?n/7R 16 50-289 Docket No. 8n 120 C DPR-50 License No, npp 73 Priority -- Category B2 Licensee: Metrnnnlitan rdison cnmnanv P.O. Box 542 Readinc. Pennsv1vania 19640 Facility Name: Three Mile Island Nuclear Station, Units 1 and 2 Inspection at: Middletown, Pennsylvania Inspection conducted: Dec mber 4-8 and 12-14,1978 Inspectors: //M7T
'date signed D.R.Haverkamp,Reacto/ Inspector
% 9. %~ t/v h 9 date signed d./R.JohVson,ReactorInspectorTrainee h $ b h e_,.~ i /v /n?
'dat'e signed ,
P. D. cto,r Inspector Trainee Approved by: / 4
^ -V /- a~- 78 g' hief, ctor Projects Section date signed
/.'R.'Kei' No. 1, NS Bra Inspection Summary:
Inspection on December 4-8 and 12-14, 1978 (Combined Report Nos. 50-289/78-23 and 50-320/78-36) Areas Inspected: Routine, unannounced inspection by three regional based inspectors of plant operations including facility tour during backshift; Technical Specification Safety Limits, Limiting Safety System Settings and Limiting Conditions for Operation compliance during reactor operations (Unit 2 only); plant cleanliness (Unit 2 only); RPS grounding system testing; stem mounted limit switches environmental qualifica-tion; and previous inspection findings. The inspection involved 7 inspector-hours onsite for Unit 1 and 54 inspector-hours onsite for Unit 2 by one NRC regional based inspector and 44 hours onsite by two inspector-trainees. Results (Unit 1): No items of noncompliance were identified. Results (Unit 2): Of the five areas inspected, one item of noncompliance was found in one area (Deficiency - failure to perform surveillance of containment isolation valves located inside containment, Paragraph 4). Region I Form 12 (Rev. April 77) l
DETAILS
- l. Persons Contacted Metropolitan Edison Company Mr. R. Barley, Unit 1 Lead Mechanical Engineer Mr. R. Bensel, Unit 2 Lead Electrical Engineer
- Mr. M. Bezilla, Unit 2 PORC Secretary Mr. J. Chwastyk, Shift Supervisor Mr. J. Floyd, Unit 2 Supervisor of Operations Mr. C. Hartman, Unit 1 Lead Electrical Engineer Mr. J. Hilbish, Station Lead Nuclear Engineer Mr. G. Hitz, Shift Supervisor Mr. K. Hoyt, Unit 2 Shift Foreman Mr. F. Huwe, Unit 2 Radiation Protection Foreman
- Mr. G. Kunder, Unit 2 Superintendent - Technical Support
- Mr. J. Logan, Unit 2 Superintendent Mr. V. Orlandi, Unit 1 Lead Instrumentation and Controls Engineer Mr. I. Porter, Unit 2 Lead Instrumentation and Controls Engineer
- Mr. M. Ross, Unit i Supervisor of Operations Mr. F. Scheimann, Jr., Unit 2 Shift Foreman Mr. J. Seelinger, Unit 1 Superintendent Mr. M. Shatto, Unit 1 PORC Secretary Mr. R. Warren, Unit 2 Lead Mechanical Engineer Mr. W. Zewe, Shift Supervisor General Public Utilities Service Corporation Mr. C. Gatto, Lead Mechanical Test Engineer Mr. R. Toole, Test Superintendent The inspector also interviewed several other licensee employees during the inspection. They included control room operators, technical and engineering staff personnel, and general office personnel.
- denotes those present at the exit interviews on December 14, 1978.
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- 2. Licensee Action on Previous Inspectinn Findings (Closed) Inspector Followup Item 289/78-02-01: LER 77-25/3L Cor-rective Action. Installation of permanent piping for seal water makeup to the RC evaporator was completed per C/M No. 455 and Work Requests 10829 and 10830. The inspector had no further questions concerning this item.
(Closed) Inspector Followup Item 289/78-13-02: LER 78-17/lT Cor-rective Action. Reduced RCS High Pressure Trip setpoints were approved by NRC:NRR per Technical Specification Amendment No. 45. The inspector had no further questions concerning this item. (Closed) Inspector Followup Item 320/78-22-01: Proper Approval of Temporary Changes Common to Units 1 and 2. Effective temporary changes applicable to both Unit 1 and Unit 2 were reviewed. The inspector verified that a Senior Reactor Operator licensed for each unit approved the temporary changes to the associated facility pro-cedures. The inspector had no further questions concerning this item. (Closed) Noncompliance 320/78-24-01: Electrode Storage Oven Temperature Less Than Required. The licensee's corrective measures were completed as described in MEC Letter to NRC Region I, Serial GQL 1532, dated September 18, 1978. The overall program for weld rod control was reviewed by GPUSC QA personnel and discussed with appropriate construction contractor representatives. During fre-quent QC inspections of work in progress, the storage and distri-bution of weld rods and the temperatures of holding and baking ovens were found to be acceptable. In addition, the use of weld rod at out-of-specification temperature conditions was evaluated. GPUSC memorandum PE/005 dated November 10, 1978, concluded that the welds made with the weld rods held at 1900F are sound, and the suscepti-bility to hydrogen cracking is no greater than if normal holding temperatures were employed. The inspector had no further questions concerning this item. (Closed) Unresolved Item 320/78-24-06: IEB 78-01 Correctiw Actions. Valoz type contact arm retainers were installed in applicab7 GE CR 120A and CR 122 relays per C/M 2-085. The modified relays were satisfactorily tested per Work Request No. 4133. The inspector had no further questions concerning this item.
4 (Closed) Unresolved Item 320/78-29-02: TP 272/1, Main Feed Pump, Exception E-27. During performance of TP 800/23, Unit Load Trans-ient Test, the plant attained 74% power with one operating main feed pump, which met the intent of resolving TP 272/1, E-27. No specific flow data were required to be annotated in TP 272/1. The inspector had no further questions concern h.J this item. (Closed) Unresolved Item 320/78-29-03: TP 330/5, Control Rod Drive Trip Test, Exception E-13. The acceptance of TP 330/5, E-13, was based on four previous acceptable tests performed per TP 330/5. No problem report was required to be written for additional opera-bility verification of the in-limit lights for Control Rods 5-9 and 6-7. The inspector had no further questions concerning this item. (Closed) Unresolved Item 320/78-29-04: GRC Quorum Requirements. Two additional GRC members we.re appointed by MEC Letter Serial GQM 4343, dated September 22,1978.to assure that GRC quorum re-quirements for members and alternates are met. The inspector re-viewed recent Unit 2 GRC Meeting Minutes and identified no inad-equacies concerning quorum requirements. The inspector had no further questions concerning this item. Preparation and Review (Closed) Unresolved Item 320/78-29-05: Written PORC minutes have been prepared of PORC Meeting Minutes. through Unit 2 PORC Meeting No. 292 (October 30-November 3,1978). The GRC review of PORC meeting minutes has been completed through PORC Meeting No. 276 (July 11-14, 1978). Subsequent written PORC meetinn minutes have been submitted for GRC review. The inspector noted that the preparation and review of PORC meeting minutes had improved and had no further questions concerning this item. (Closed) Unresolved Item 320/78-29-07: Control of Portable Fire Extinguishers. The inspector reviewed Procedure PM-M-8, Portable Fire Extinguisher Inspection, Revision 0, which provides require-ments to insure that portable fire extinguishers are properly inspected on a monthly frequency. The inspector noted that PM-M-8 appears adequate for future control of fire extinguishers. The inspector toured portions of the auxiliary building and turbine building at various times during this inspection and found no ex-amples of missing portable fire extinguishers. The inspector had no further questions concerning this item.
4 5 (Closed) Inspector Followup Item 320/78-29-08: Unplugged Piping Penetration. The fuel oil storage tank cross-connect pipe pene-
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tration has been plugged per ECM 5-9085. The inspector had no l further questions concerning this item. (Closed) Unresolved Item 320/78-32-01: Runback Rate Test. The ' acceptance criteria of TP 800/31 for runback rate testing was re-vised such that unit load demand called for a runback rate of 30_+2% per minute. The revised acceptance criteria was met during a retest completed on October 26, 1978. The inspector had no further questions concerning this item. (0 pen) Inspector Followup Item 320/78-32-07: LER 78-5-4/3L Cor-rective Action. The qualification of Siemans-type operators used with CA-V3, CA-V4A and CA-V4B has not yet been detemined by the licensee. MEC Letter Serial GQM 5305, dated November 15, 1978 stated that the Siemans operators are considered adequately qual-ified for temporary use inside containment, based on licensee re-view of documentation provided by the valve vendor. The A,E is attempting to determine the extent of " temporary". Because these operators use Class B insulation, the long-term temperature effects are not sufficiently known to allow the operators to be left inside containment permanently. Replacement of these operazors is planned for the earliest convenient outage. Final licensee evaluation of Siemans operators usage and replacement will be reviewed during a subsequent inspection.
- 3. PlantTour(Units 1and2_),
Upon arrival at the site at 6:15 a.m. on December 4,1978, the ! inspector proceeded directly to the Unit 1 and Unit 2 Control Rooms to observe plant operations during off-normal hours. Con-trol Room manning t,nd control board monitoring instrumentation and equipment controls were observed for conformance with appli-cable Technical Specification requirements. The inspector then conducted a tour of the Unit 2 Auxiliery Building to check for general cleanliness and housekeeping conditions, potential fire hazards and adequacy of radiation controls. The tour was com-pleted at 8:30 a.m. Findings were acceptable, except as noted below.
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-- Several radiation control discrepancies were observed by the inspector during the Unit 2 Auxiliary Building tour. Used protective clothing was laying on the floor and used rubber boots and gloves were laying on the step-off pad at the con-trol point entry to the B Decay Heat Vault. No barricade was in place at the entry to the A Decay Heat Vault, which was posted as a radiation area. No radiation area signs were posted at the entries to the MU-P-lc and MU-T-1A cubicles, which were identified by radiation work pennits as radiation areas. The radiation work permit for the seal return cooler cubicle was laying on the floor at the entry to the cubicle.
The Unit 2 radiation protection foreman also identified the above discrepancies during a facility tour conducted at the same time as, but not in company with, the inspector. Although these items were promptly corrected, the inspector expressed concern over the appa-rent degradation in proper radiation protection control during the. preceding weekend. The discrepant conditions resulted from a com-bination of inadequate training and insufficient designation of responsibilities regarding operations and radiation protection per-sonnel. Licensee representatives stated that appropriate correc-tive action would be taken to ensure adequate radiation protection controls are maintained in the future. The inspector conducted two subsequent tours of the Unit 2 Auxiliary Building during this inspection and noted that radiation protection controls were accept.able. The effectiveness of licensee actions to maintain proper controls for protective clothing disposal and radiation area posting / barricading will continue to be reviewed during routine NRC inspections. The inspector had no further questions concerning this item at this time.
- 4. Review of Safety Limits, L!miting Safety System Settings and Mmiting Conditions for Operation The inspector observed process instrumentation monitoring current operations on December 4-6 and 13-14,1978 and reviewed records of reactor operations during February-December 1978. The following loos and records were reviewed on a sampling basis.
-- Shift Foreman Log
-- Control Room Log Book l
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-- Operating Procedure (OP) 2102-1.1, " Unit Heatup," Revision 16; completed December 1,1978
-- OP 2102-1.2, " Approach to Criticality," Revision 5 (TCN 2-78-669);
completed December 3,1978
-- OP 2102-1.3, " Unit Startup," Revision 10 (TCNs 2-78-665, 2-78-667, 2-78-670,2-78-700,2-78-709); in progress on December 7, 1978
-- OP 2102-2.1, " Power Operations," Revision 9 (TCN 2-78-701);
control room file copy
-- OP 2102-3.1, " Unit Shutdown," Revision 6 (TCNs 2-78-612, 2-78-654,2-78-683); completed October 29, 1978
-- OP 2102-3.2, " Unit Cooldown," Revision 10 (TCNs 2-78-615, 2-78-671); completed September 23, 1978
-- OP 2102-4.1, " Reactor Building Purge and Purification," Re-vision 3; partially completed February 17, 1978
-- OP 2103-1.1, " Filling and Venting the Reactor Coolant System,"
Revision 8 (TCN 2-78-694); partially completed September 24, 1978
-- OP 2103-1.2, " Soluble Poison Concentration," Revision 4; con-trol room file copy
-- OP 2103-1.3, " Pressurizer Operation," Revision 3; partially completed September 16, 1978
-- OP 2104-1.1, " Core Flooding System," Revision 8; partially
- completed August 22, 1978
-- OP 2104-1.2, " Makeup and Purification System," Revision 11 (TCN2-78-688); completed November 19, 1978
-- OP 2104-1.4, " Reactor Building Spray," Revision 3; Appendix A Valve Lineup completed July 14, 1978
-- OP 2104-3.3, " Decay Heat Closed Cooling Water System," Revis-ion 5; completed August 22, 1978
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- OP 2104-6.2, " Emergency Diesels and Auxiliaries," Revision 8; ~
completed May 30 and December 8, 1978
-- OP 2104-0.3, " Emergency Feedwater," Revision 4; Appendix A Valve Lineup completed November 17, 1978
-- OP 2104-6.4, " Hydrogen Recombiner Operation," Revision 2; con-trol room file copy
-- OP 2104-6.5, " Hydrogen Control System," Revision 1; control room file copy 1
-- OP 2105-1.1, " Nuclear Instrumentation," Revision 2; completed October 9, 1978
-- OP 2105-1.2, " Reactor Protection System," Revision 4; partially completed August 25, 1978
-- OP 2105-1.3, " Safety Features Actuation System," Revision 2; partially completed October 9,1978
-- OP 2105-1.9, " Control Rod Drives," Revision 5; completed (un-dated)
-- OP 2107 . 2, " Class 1E Electrical System," Revision 5; com-pleted November 18, 1978
-- SurveillanceProcedure(SP) 2301-51, " Shift and Daily Checks,"
Revision 12 (TCNs 2-78-661, 2-78-687, 2-78-690); completed August 27-September 3, September 13-26, October 3-15, November 3-10, and December 1-6, 1978
-- SP 2301-3D1, "RCS Inventory," Revision 2; completed during October 1-December 11, 1978
-- SP 2301-Wl, " Weekly Surveillance Checks," Revision 4 (TCNs 2-78-657,2-78-711); completed during October 5-December 7, 1978
-- SP 2301-W2, " Station Storage Batteries and Chargers Weekly Check," Revision 2; completed during October 4-December 6, 1978 e ~ , - --- , - - - ---r -- -. - - - - - . - - - - -, - - - - ,- ,
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-- SP 2301-M2, " Boron Injection System Valve Lineup Verifica-
' tion," Revision 2; completed durir g July 26-December 8,1978
-- SP 2301-M4, " Remote Shutdown Instrumentation," Revision 3; completed during August 28-Decembea 5, 1978
-- SP 2301-MS, "RCP Seal Return Measuroment," Revision 1; com-pleted during August 28-December 6, 1978
-- SP 2301-M6, " Core Flood Tank - Isolation Valve Breaker Posi-tion Verification," Revision 2; completed during August 28-December 4, 1978
-- SP 2301-M8, " Containment Integrity Verification," Revision 6
' (TCN 2-78-673); completed during August 23-December 7,1978
-- SP 2301-Mll, "DHCCW Valve Lineup Verification," Revision 3; completed during August 10-November 10, 1978
-- SP 2301-Ql, " Station Storage Batteries," Revision 2; completed August 16 and November 22, 1978
' -- SP 2303-M13, " Hydrogen Purge Cleanup System," Revision 1; completed during March 22-November 17, 1978 ' -- SP 2303-M14A/B/C/D/E, " Emergency Feed System Valve Lineup Verification and Operability Test; and Turbine Driven E.F. Pump Operability Test," Revision 8; completed during July 20-December 2, 1978
-- SP 2303-M16A/B/C/D, " Emergency Diesel Generator and Cooling Water Valve Operability Test," Revision 8; completed during October 2-December 11, 1978
-- SP 2303-M37, " Hydrogen Mixing System - Remote Start and Oper-ability Check," Original; completed during August 10-December 10, 1978
-- SP 2303-Q3, " Hydrogen Recombiner Functional Test," Revision 2; completed October 11, 1978
-- SP 2304-W1 " Borated Water Source Concentration Test," Original; j
completed during August 7-December 12, 1978
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-- SP 2304-M1, " Core Flood Tank Boron Concentration," Revision I ~
1; completed during July 25-December 8,1978 l
-- SP 2304-SA1, Building Spray NaOH Tank Concentration and Volume," Revision 2; completed September 26, 1978
-- SP 2311-2, " Minimum Temperature for Criticality," Original; control room file copy
-- SP 2311-5, " Containment Integrity," Revision 5 (TCN 2-78-718);
completed during August 25-December 6, 1978
-- SP 2601-M1, " Reclaimed Boric Acid Tank Temperature," Original; completed during August 2-December 2,1978 The observations and records review were conducted to verify that startup, power and/or shutdown reactor operations were in conform-ance with Technical Specification safety limits, lin.iting safety system settings, and limiting conditions for operation.
Acceptance criteria for the above items included selected require-ments of facility operating procedures and the following Technical Specifications (listed according to their respective systems).
-- Reactivity Control and Power Distribution Technical Specifica-tions 3.1.1.2, 3.1.1.4, 3.1.2.2, 3.1.2.4, 3.1.2.7, 3.1.2.9, 3.1.3.1, 3.1.3.3, 3.2.1, and 3.2.4
-- Instrumentation Technical Specifications 2.2.1 (Table 2.2-1 items 2,3,5,6 and 9), 3.3.1.1 Table 3.3-1 items 2, 3, 5, 6 and 9), 3.3.2.1 (Tables 3.3-3 and 3.3-4 items 1.b and 2.b),
3.3.3.5 (Table 3.3-9 meter items 1 and 3; indicator item 1 and patch point items 1 and 4)
-- Reactor Coolant System Technical Specifications 2.1.1, 2.1.3, 3.4.1, 3.4.4, 3.4.6.2, and 3.4.9.1
-- Emergency Core Cooling Systems Technical Specifications 3.5.1 and 3.5.4
-- Containment Systems Technical Specifications 3.6.1.4, 3.6.1.5, 3.6.1.7, 3.6.2.2, 3.6.3.1, 3.6.4.2 and 3.6.4.4 l
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-- Plant and Electrical Power Systems Technical Specifications
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3.7.1.2, 3.7.1.3, 3.7.3.2, 3.8.1.1 and 3.8.2.3 The items observed and reviewed by the inspector were acceptable, unless otherwise noted below.
! -- The inspector noted the following examples of improperly or inadequately completed operating procedures:
- a. OP 2102-1.3 (in progress on December 7,1978) - Step 4.1.40 and subsequent steps were performed, but were not initialed as being completed; 1'
- b. OP 2102-3.2 (completed September 23, .1978) - Steps 3.6, i
- 3.7, 4.2.2 and 4.6.a were not initialed as being completed;
- c. OP 2102-4.1 (partially completed February 17, 1978). All prerequisite steps were not initialed as being completed i
and Appendix A Valve Lineup was not fully completed;
- d. OP 2103-1.1 (partially completed September 24, 1978) -
! Section 3.1 step 8, Section 3.2 steps 10-35, 41-49 and 51 and Section 4.2 steps 2 and 4 were not initialed as being completed;
- e. OP 2103-1.2 - Various procedural evolutions had been performed, but no completed procedures were in the con-trol room files; l
- f. OP 2103-1.3 (partially completed September 16, 1978) -
Steps 4.1.5.7 and 4.1.5.8 were performed, but were not i initialed as being completed;
- g. OP 2104-1.1 (partially completed August 22,1978) - Steps 3.1 and 3.2 were not initialed as being completed;
- h. OP 2104-1.2 (completed November 19, 1978) - Appendix A l Valve Lineup was not fully completed;
- i. OP 2104-1.4 (Appendix A Valve Lineup completed July 14, 1978) - No prerequisite or startup procedure steps were initialed as being completed; l
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- j. OP 2104-6.2 (Undated) - Many steps were not initialed as being completed, and the partially completed procedure was not annotated with the date of performance;
- k. OP 2104-6.2 (portions completed on May 30 and December 8, 1978) - Procedure excerpts for diesel generator manual start evolutions were in the control room files vice the entire procedure;
- 1. OP 2104-6.3 (Appendix A Valve Lineup completed November 17, 1978) - No prerequisite or startup procedure steps were initialed as being completed;
- m. OP 2105-1.2 (partially completed August 25, 1978) - Steps 4.4,4.5.B(1)-(14)and4.5.B(18)-(26)werenotinitialed as being completed;
- n. OP 2105-1.3 (partially completed October 9, 1978) - Sec-tion 4.2 steps were not initialed as being completed; and,
- o. OP 2105-1.9 (Undated) - Steps 4.2.1.17, 4.2.1.18, 4.2.8.1, 4.2.8.2.1 and 4.2.8.2.2 were not initialed as being com-pleted and the partially completed procedure was not annotated with the date of performance.
The inspector stated that, based on the number of discrepancies noted above, corrective action was necessary to assure conformance with licensee administrative controls for operating procedure impiementation and review. Licensee representatives stated that operr. tors would be reminded of their responsibilities for proper procedure completion. This item is unresolved pending review of licensee corrective actions and selected, completed operating procedures during a subsequent inspection. (320/78-36-01)
-- The inspector noted the following examples of improperly annotating unused control room controlled file and/or working copies of operating procedures:
- a. OP 2102-3.2 - File and working copy steps 4.27.1 and 4.28 were initialed as being completed;
- b. OP 2102-4.1 - Several working copy prerequisite and purge procedure steps were initialed as being completed; and,
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- c. OP 2103-1.2 - Working copy Page 36.0 was annotated with numbers.
The above file and working copies of operating procedures were stored in control room file cabinets for controlled use. These i procedures should have no annotations, except references to effec-tive TCNs or cancelled TCNs. Licensee representatives stated that a full page audit of file and working copies of control room pro-cedures was scheduled to be performed. In addition to page check-ing for procedure completeness, the pages will be reviewed for improper annotations. This item is unresolved pending completion of the scheduled procedure audit. (320/78-36-02)
-- SP 2301-51 incorporates various Technical Specification sur-veillance requirements to be performed at once per shift, 12
) hour or daily frequencies. The inspector noted the following examples of improperly implementing SP 2301-S1: ) a. Boron reductions were made on 5 occasions without com-pleting Appendix H, as required by SP 2301-S1; i
- b. Performer and/or approver signatures were missing on several occasions;
- c. Various parameters were not recorded or were incorrectly recorded on several occasions, including containment atmosphere and gaseous monitoring system channel checks, RPI/ API / group control rod positions, condensate storage tank level, operational mode, R.B. purge valve accumulated time, RPS channel check, source range flux, BWST temper-ature, R.B. pressure deviations and pump / flux contact monitors; and,
- d. Unapproved minor changes were made to required data, i.e.
"NR" to "WR", of SP 2301-51 on six occasions.
! The inspector stated that except as described above, all portions of the SPs 2301-51 had been fully and properly completed. Licensee representatives stated that appropriate action would be taken to assure that SP 2301-51 is properly implemented in the future. This item is unresolved pending review of licensee corrective actions - and selected completed SPs 2301-51 during a subsequent inspection. (320/78-36-03) l i
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-- SP 2301-M4 incorporates Technical Specification Surveillance ,
Requirement 4.3.3.5 monthly channel checks of remote shut-down monitoring instrumentation. Completed SP 2301-M4, dated December 5, 1978, listed several remote shutdown instrument
- values, which were at or slightly exceeded the acceptance
. criteria of within 24 of corresponding control room instru-4 ment values. Prior to the end of the inspection, SP 2301-M4 was perfonned again with the results being acceptable. The inspector noted that the prescribed acceptance criteria was not appropriate for all instrument comparisons. In some cases, the acceptance criteria appeared more stringent than necessary; ' in other cases, the 2% tolerance did not provide a meaningful comparison of parameters. Licensee representatives stated that SP 2301-M4 would be revised to provide appropriate acceptance criteria. This item is unresolved pending revision
- of SP 2301-M4. (320/78-36-04)
-- SP 2301-MS, Revision 1, was issued on September 29, 1978 to provide an improved method of calculating RCP seal return flow.
The inspector noted that the revised procedure omitted a square i l root sign in the equation used for the flow computation. This l' error resulted in higher than actual calculated seal return flows from each pump for the past three months. The error. was conservative with respect to Technical Specification RCS leakage limits. Prior to tN end of the inspection, a TCN was prepared to provide the a rrect equation. The inspector had no further questions concerning this item. 1
-- The inspector noted two inadequacies with SP 2303-M13, Revis-l ion 1, dated August 9, 1977. The procedure requires record- ! ing of the time on Appendix C of OP 2102-4.1, when R.B. purge exhaust isolation valve AH-V3A is opened in Modes 1 and 2.
l Technical Specification 3.6.1.7, which became effective on j February 8, 1978, requires the accumulated time with any con- , i tainment purge supply and/or exhaust valve open, when in Modes
' 1, 2, 3 and 4, to be < 90 hours for the preceding 365 days.
In addition, OP 2102-T.1 Revision 3, dated April 18,1978, de-leted Appendix C and required recording of the time, when these l valves are open, in a log book kept at control room panel i 25 where the valves are operated. SP 2303-M13 requires revis-ion to be consistent with T.S. 3.6.1.7 and OP 2102-4.1 require-ments. The log book requires review to ensure that the accumu-lated time is correct with respect to completing SP 2303-M13, as well as Reactor Building purge and depressurization opera-tions. This item is unresolved pending completion of the l above corrective actions. (320/78-36-05) i (
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-- Technical Specification Surveillance Requirement 4.6.1.1.a.1 - states that, for certain valves, blind flanges and deactivated ,
automatic valves which are located inside containment, these l penetrations shall be verified closed curing each cold shut-down (Mode 5) except that verification of these p'enetrations being closed need not be performed more often than once per 92 days. SP 2311-5 incorporates this requirement to verify that containment isolation valves and flanges inside contair. ment are closed, and, in addition, incorporates. separate require-ments to verify that airlock door seal, leakage is within limits. The valves inside containment were verified closed during performance of SP 2311-5 on tugust 26, 1978, while in Mode 5. The plant entered Mode 4 on'A.ugust 28, 1978 and was subsequently in Mode 5 during November:10-20 and 23-30,1978. The plant has been in Mode 4 or above since December 1,1978. The air lock door seal leakage portion of SP 2311-5 has been properly performed throughout this period, but the valve verification portion of SP 2311-5. has not been completed since August 26, 1978. Failure to perfonn surveillance of valves inside containment is considered an Item of Noncompliance at the Deficiency level of severity. (320/78-36-06)
- 5. Cleanliness (Unit 2)
- a. Program Review The inspector reviewed the following procedures.
-- Station Administrative Procedure (SAP) 1008, " Good House-keeping," Revision 4
-- SAP 1020, " Cleanliness Requirements," Revision 6
-- SAP 1030, " Control of Access to Prirrary System Openings,"
Revision 2
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-- SAP 1034 (Unit 2 Only), " Control of Combustible Materials,"
- Original 1
The procedures were reviewed to verify that written adminis-trative controls have been established to assure adequate
- housekeeping and cleanliness and that the procedures used j included requirements for the following items.
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-- Material accountability in critical clean areas such as openings in the primary system, work on primary system components, and the refueling area
-- Cleaning primary system components that have been re-paired or replaced
-- Returning excess equipment or material to applicable storage areas of the facility .
-- Prompt removal from the facility of combustible material and debris Acceptance criteria for this review included applicable re-quirements of Technical Specifications, ANSI N18.7-1972 and Regulatory Guide 1.39.
Findings were acceptable,
- b. Implementation Review The inspector interviewed selected licensee personnel to verify that they are cognizant of and use the above procedures for the control of housekeeping and cleanliness. Additionally, at various times during the inspection, the inspector conducted tours of the Reactor Bailding, Auxiliary Building, Turbine
- Building and Control Building to verify that the program for housekeeping and cleanliness control is effective.
The inspector's findings regarding these items were acceptable.
Areas which needed housekeeping improvements were discussed with licensee representatives. The conditions observed did not cause an immediate fire or safety problem.
- 6. Reactor Protection System Grounding System Testing (Units 1 and 2)
On March 8, 1978, B&W notified the NRC about a potential RPS ground-ing safety concern, pursuant to 10 CFR Part 21. The B&W letter to the NRC, dated March 9, 1978 documented the evaluation of this con-cern, wherein it was postulated that a loss of ground could cause the NI/RPS to fail to perform its intended function. i w ,- ,-. -.. - - - .... _ , ,- - -.- -. . - - . . , . , , - - . . - - - - - . . - . .
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- The preliminary safety concern proposed the following hypothesis:
a NI/RPS channel may experience a loss of ground to its instrument comon without the loss of ground being evident; given this con-dition, a single postulated failure in one channel can leave the RPS in an unanalyzed condition. The concern exists for those plants that utilize a ground as an active return path, including TMI Units 1 and 2. B&W recomended that applicable facilities institute a periodic test of the NI/RPS to assure that ground has not been lost. NRC:NRR determined that this matter does not represent a significant problem. - However, the applicable licensees should review the ground-ing system for their plants in accordance with the recomendations of B&W and should have an ongoing test program to verify, on a periodic basis, the ground continuity of the NI/RPS. As stated in MEC Letter to NRC:NRR, Serial GQL 0762, dated April 25, 1978, the licensee has reviewed the concern raised by B&W and disagrees with the B&W finding. The possibility of losing ground within the NI/RPS was evaluated by Unit 1 and Unit 2 PORCs and by MEC's Generating Engineering Section, which agreed that a double failure would be required to cause the system to be degraded. There-fore, the B&W concern was not considered to represent a substantial safety hazard. Nonetheless, a loss of RPS ground continuity check has been implemented for TMI Unit 1. Surveillance Procedure 1303-4.1 i " Reactor Protection System," Revision 29, dated October 16, 1978, includes checks fcr a loss of ground continuity during performance of weekly protective channel coincidence logic surveillance. These checks will identify the loss of connection of the plant ground system to one or more NI/RPS channel instrument comons. Licensee representatives stated that similar ground continuity checks will be implemented for TMI Unit 2 by January 31, 1979. The inspector had no further questions concerning this matter at this time. i 7. Stem Mounted Limit Switches - Environmental Qualificiation (Units l 1 and 2) NRC:NRR/ DSS has established that power operated containment isola-tion valve position indication to the control room operator is essential during and following a LOCA. At other nuclear stations certain environmentally unqualified stem mounted limit switches (SMLSs) were used inside containment to provide such indication. Those facilities have been required to replace the unqualified i NAMCO-type SMLSs. l
18
- The inspector reviewed the applicability of this problem at both TMI units. With respect to Unit 1, no NAMCO-type SMLSs are used inside containment for containment isalation valve position indi-cation. Relative to Unit 2, eight NAMCO-type Model EA 740 20000 '
SMLSs are used inside containment for position indication of RB purge supply and exhaust valves. The inspector verified that these NAMCO SMLSs were a different model than those identified as environ ~- mentally unqualified. Licensee repre.<entatives stated that the limit switches were qualified but no documentation was available for the inspector's review onsite. The licensee is conducting a generic review of the environmental qualification of safety-related electrical equipment at both units in response to IE Circular 78-08 (
Reference:
Inspector Followup Item 320/78-29-06). This item is unresolved pending verification that the above Unit 2 NAMCO-type SMLSs are qualified. This will be accomplished during a subsequent inspection at the corporate office. (320/78-36-08)
- 8. Unresolved Items Unresolved items are matters about which more information is re-quired in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items disclosed during the inspection are discussed in Paragraphs 4 and 7.
- 9. Exit Interview The inspector met with licensee representatives (denoted in Para-graph 1) at the conclusion of the inspection on December 14, 1978.
The inspector summarized the purpose and scope of the inspection and the findings.
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Docket Nos. 50-289 50-320,f 2 9 JAN 1979 Metropolitan Edison Company ATTN: Mr. J. G. Herbein Vice President - Generation P. O. Box 542 Reading, Pennsylvania 19640 Gentlemen:
Subject:
Combined Inspection 50-289/79-01; 50-320/79-01 This refers to the inspection conducted by Mr. D. Haverkamp of this office on January 8-11, 1979 at your corporate office and at Three Mile Island Nuclear Station, Units 1 and 2, Middletown, Pennsylvania of activities authorized by NRC License Nos. DPR-50; DPR-73 and to the discussions of our findings held by Mr. Haverkamp with Messrs. G. Troffer and G. Kunder at the conclusion of the inspection. Areas examined during this inspection are described in the Office of Inspection and Enforcement Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector. Within the scope of this inspection, no items of noncompliance were observed. In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If this report contains any infomation that you (or your contractor) l believe to be proprietary, it is necessary that you make a written i application within 20 days to this office to withhold such information from public disclosure. Any such application must be accompanied by an affidavit executed by the owner of the infomation, which identifies the document or part sought to be withheld, and which contains a statement of reasons which addresses with specificity the items which will be considered by the Comission as listed in subparagraph (b) (4) of Section 2.790. The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room. l
.. e >
Metropolitan Edison Company 2 2 9 JAN 1979 No reply to this letter is required; however, if you should have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely, E on . Brunner, Chief Reactor Operations and Nuclear Support Branch
Enclosure:
Office of Inspect!on and Enforcement Combined Inspection Report Numbers 50-289/79-01; 50-320/79-01 cc w/ enc 1: E. G. Wallace, Licensing Manager J. J. Barton, Project Manager R. C. Arnold, Vice President - Generation L. L. Lawyer, Manager - Generation Operations - Nuclear G. P. Miller, Superintendent J. L. Seelinger, Unit 1 Superintendent J. B. Logan, Unit 2 Superintendent G. A. Kunder, Unit 2 Superintendent - Technical Support I. R. Finfrock, Jr. Mr. R. Conrad G. F. Trowbridge, Esquire Miss Mary V. Southard, Chairman, Citizens for a Safe Environment (Without Report) i bec w/ enc 1: IE Mail & Files (For Appropriate Distribution) Central Files
- Public Document Room (PDR)
Local Public Document Room (LPDR) Nuclear Safety Information Center i Technical Infor ation Center (TIC)(HSIC) REG:1 Reading Room . Region Directors (III, IV)(Report Only) Comonwealth of Pennsylvania Miss Mary V. Southard, Chairman, Citizens for a Safe Environment
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.i. NUCLEAR REGULATORY COMMISSI i '
0FFICE OF INSPECTION AND ENFORCEMENT Region I 50-289/79-01 Report No. 50-320/79-01 50-289 Docket No. 50-320 DPR-50 C License No. DPR-73 Priority -- Category C Licensee: Metropolitan Edison Company P. O. Box 542 Reading, Pennsylvania 19640 Facility Name: Three Mile Island Nuclear Station, Units 1 and 2 Inspection at: Middletown, Pennsylvania and Reading, Pennsylvania Inspection conducted: . January 8-11, 1979 Inspectors: w /-24-79 D. R. Haverkamp, Reactc[/ Inspector date signed date signed date signed Approved b : ,
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'date ' sign'ed R. R. KeimIg, Chief, Reactor Projects Section No.1, RO & NS Branch Inspection Summary:
Inspection on January 8-11,1979 (Combined Report Nos. 50-289/79-01; 50-320/79-01) Areas Inspected: Routine, unannounced inspection by a regional based inspector of plant operations including shift logs and records and facility tour during normal hours (Unit 2); plant operations during backshift (Unit 2); selected licensee i events and periodic reports (Unit 2); and, licensee followup to IE Circular I 78-08 and previous inspection findings (Units 1 and 2). The inspection involved 4 inspector-hours onsite for Unit 7.,,16 inspector-hours onsite for Unit 2, and B inspector-hours at the corporate office by one NRC regional based ir.spector. Results: No items of noncompliance were identified. Region I Form 12 (Rev. April 77) .
i i L DETAILS
- 1. Persons Contacted Metropolitan Edison Company - Three Mile Island Mr. R. Barley, Unit 1 Lead Mechanical Engineer
*Mr. M. Bezilla, Unit 2 PORC Secretary Mr. C. Hartman, Unit 1 Lead Electrical Engineer Mr. K. Hoyt, Unit 2 Shift Foreman
*Mr. G. Kunder, Unit 2 Superintendent - Technical Support Mr. J. Logan, Unit 2 Superintendent Mr. F. Scheimann, Jr., Unit 2 Shift Foreman Mr. M. Shatto, Unit 1 PORC Secretary Mr. B. Smith, Shift Supervisor Mr. W. Zewe, Shift Supervisor Metropolitan Edison Company - Corporate Office i
**Mr. R. Harding, Unit 2 Lead Licensing Engineer
**Mr. G. Troffer, Manager - Generation Quality Assurance The inspector also interviewed several other licensee employces during the inspection. They included control room operators, licensing and engineering staff personr.el, and general office personnel.
- denotes those present at the exit intenlisw onsite on January 10, 1978.
** denotes those present at the exit: interview at the corporate office on January 11, 1979.
- 2. Licensee Action on previous Inspection Findings (Units 1 and 2)
(Closed) Inspector Followup, Item 289/78-13-01: LER 78-08/1T Corrective Action. The plant continues to operate with a low water level in the OTSGs when at low power levels. Various options which would allow flooded OTSG nozzel startup operations are being considered by the licensen. However, such operation will not be performed without NRC/N1R approval. The inspector had no further questions concerning this item. I
- _ . , _ - . . _ , , _ . _ - . - - _ -, ,, ,_ - ~ ____, - - , _ . _ _ , _ _ . . _ - --, _ -
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3 (Closed) Unresolved Item 289/78-19-02: LER 78-24/1T Corrective Action. Temporary Change Notices 78-261 through 78-267 have l been issued to incorporate revised heatup/cooldown limits in applicable operating procedures. TSCR #88, dated January 4, 1979, has been submitted to NRC/NRR to revise applicable Tech-nical Specifications. The inspector had no further questions concerning this item. (Closed)UnresolvedItem 289/78-19-03: LER 78-25/1T Corrective Actions. TCN 78-269 was issued to SAP 1002 to ensure proper . . selection and testing of backup E.S. equipment, when taking emergency safeguards components out-of-service. Permanent revision of SAP 1002 is in progress. The inspector had no fur-ther questions concerning this item. (Closed)UnresolvedItem 289/78-19-05: Licensee Review of IE Circular 78-16. IEC 78-16 has been reviewed by PORC and Gener-ation Engineering - Electrical Section. The plant has some Limitorque valves of the type described, however, manual operation is infrequent. Present procedural guidance for valve operation and maintenance is considered adequate. Vendor comments concern-ing proper valve operation were sent to the training department for discussion in the operator requalification program. The inspector had no further questions concerning this item. (Closed) Unresolved Item 320/78-29-06: Licensee Review of IE l Circular 78-08. Licensee review of environmental qualification of safety-related electrical equipment has been completed, as
- described in paragraph 3 of this report. The inspector had no further questions concerning this item.
(Closed) Noncompliance 320/78-32-04 and Unresolved Item 320/78-32-05: Administrative Controls for Jumpers and Lifted Leads. A licensee audit of jumpers and lifted leads has been completed. No further examples of improper administrative control of these items were noted by the inspector. SAP 1013 does not require revision to require more stringent controls or to include specific controls for gagging devices at this time. The inspector had no further questions concerning these items.
\
4 (Closed) Unresolved Item 320/78-36-08: Environmental Qualification Testing of NAMCO - Type SMLSs. NAMCO-type stem mounted limit switches, used for position indication of R.B. purge supply and exhaust valves, were tested for environmental qualification, as described in paragraph 3 of this report. The inspector had no further questions concerning this item.
- 3. IE Circular 78-08 Followup (Units 1 and 2)
The inspector reviewed the licensee's followup actions regarding. IE Circular 78-08, " Environmental Qualification of Safety-Related Electrical Equipment at Nuclear Power Plants," dated May 31, 1978. The review included discussions with licensee personnel and review of the following selected records at the corporate office. Generation Division Service Requests 780260, 780261, 780292, and 780302 (used to assign responsibility for review of IE Circular 78-08 and referenced material)
-- Electrical Connector / Penetration Concern Summary (Licensee drafted)
Union of Concerned Scientists Sumary (Licensee drafted)
-- Sumary of IE Circular 78-08 Review (Licensee drafted)
Metropolitan Edison Company (MEC) memorandum serial GEM 5258, dated November 13, 1978 (list of electrical compo-nents located inside containment which are required to function following a LOCA/ steam line break at TMI-1)
-- Burns and Roe, Inc. letter to MEC serial 4301-GP, dated November 9,1978 (TMI-2 electrical equipment environmental qualification)
-- MEC memorandum serial GQM 5162, dated November 8,1978 (verification of no failures of electrical components located inside containment at TMI-1 and TMI-2 as a result of adverse environmental conditions)
-- MEC memorandum serial GEM 5147, dated November 7, 1978 (description of engineering review and verification that installed safety-related electrical equipment at TMI-l is environmentally qualified)
i 5 GPU/ Burns and Roe documentation sent to MEC (Review of TMI-2 safety-related electrical equipment in relation to IE Circular 78-08 concerns) Specification 2555-100 Containment Purge Isolation Butter-fly Valves MEC memorandum serial GQM 5619, dated December 5,1978 (Field verification of electrical components installed at TMI-1) Selected documentation of TMI-2 component changes / modifications to provide environmentally qualified electrical equipment Selected environmental qualification test report data for electrical components installed at TMI-i and TMI-2 The inspection. purpose,:scooe and acceptance criteria reaarding licensee followup to IEC 78-08 were as described in 0IE Inspection Report No. 50-320/78-29, paragraph 8. Findings were acceptable, except as described below. Field verification of electrical components installed at TMI-1 has not yet been completed. MEC memorandum GQM 5619 states that such verification is to be performed by MEC QC personnel during the 1979 refueling outage commencing in mid-February. The QC surveillance report is scheduled to be published by April 1, 1979. This item is unresolved, pending NRC review of the TMI-1 field verification (289/ 79-01-01).
- 4. Review of Plant Operations (Unit 2)
- a. Shift Logs and Operatino Records The inspector reviewed the following logs and records.
l Shift Foremen Log, Control Room Log Book, Control Room Operator's Log Sheets, Primary Auxiliary Operator's Log-Tour Readings, Primary Auxiliary Operator's Log-Liquid Waste Disposal Panels, Secondary Auxiliary Operator's Log Sheets, and Auxiliary Operator Log Sheets-Out-Building Tour, dated October 16 - December 31, 1978. l
6 1 Shift and Daily Checks, dated October 16 - December 31, 1978. Jumper, Lifted Lead, and Mechanical Modifications Logs (active and cleared); entries made during October 16 - December 31,1978, and selected active entries. Fire System Removal from Service Notification Log; entries made during October 16 - December 31, 1978. Applications for Apparatus to be Taken Out of Service; those active on January 10, 1979 and those cleared, dated December 28, 1978 - January 9, 1979. Do Not Operate and Caution Tag Logs; entries made during October 16 - December 31, 1978. Transient Cycle Log Book; entries made during October 16 - December 31, 1978. Unit 2 Operations Department Memos 2-78-17 through 2-78-25. The logs and records were reviewed to verify the following items. Logkeeping practices and log book reviews are conducted in accordance with established administrative controls. Log entries involving abnormal conditions are sufficiently detailed. Operatin orders do not conflict with Technical Specifi-cations TSs). Jumper Log and tagging log entries do not conflict with TSs. Jumper / lifted lead / mechanical modification and tagging operations are conducted in confornance with established administrative controls. Problem identification reports confirm compliance with TS reporting and LCO requirements. l 1
l s l 7 Acceptance criteria for the above review included inspector judgment and requirements of applicable Technical Specifications and the following procedures.
-- Station Administrative Procedure (SAP) 1002, " Rules for the Protection of Employees Working on Electrical and Mechanical Apparatus," Revision 13.
-- SAP 1010. " Technical Specification Surveillance Program."
Revision 12. TCN 2-78-736.
-- SAP 1011. " Controlled Key Locker Control," Revision 16. l
-- SAP 1012. " Shift Relief and Log Entries," Revision 8.
-- SAP 1013. " Bypass of Safety Functions and Jumper Control,"
Revision 7.
-- SAP 1016. " Operations Surveillance Program," Revision 12.
-- SAP 1033, " Operating Memos and Standing Orders," Original.
-- SAP 1037, " Control of Caution and DNO Tags," Revision 1.
No items of noncompliance were identified.
- b. Plant Tour Upon arrival at the site at 6:45 a.m. on January 8,1979, the inspector proceeded directly to the Unit 2 Control Room to observe plant operations during off-nomal hours. Control Room manning and control board monitoring instrumentation and equipment were observed for confomance with applicable Technical Specification requirements. The inspector then conducted a tour of the Unit 2 Auxiliary Building to check for general cleanliness and housekeeping conditions, potential ;
- fire hazards and adequacy of radiation controls. The tour l was completed at 8
- 45 a.m. Findings were acceptable.
At various times on January 9-10, 1979, the inspector conducted tours of the following accessible plant areas. ,
-- Auxiliary Building
-- Turbine Building l
l l l
t 8
-- Control and Service Building Control Room
-- Switchgear Rooms
-- Inverter and Battery Rooms
-- Makeup Pump Rooms The following observations / discussions / determinations were made.
-- Control Room and local monitoring instrumentation for various components and parameters was observed.
-- Radiation controls established by the licensee, including the posting of radiation and high radiation areas, the condition of step-off pads, and the disposal of protective clothing, were observed. Radiation Work Permits used for entry to radiation and controlled areas were reviewed.
-- Plant housekeeping, including general cleanliness conditions and storage of materials and components to prevent safety and fire hazards, were observed.
-- Systems and equipment in all areas toured were observed for the existence of fluid leaks and abnormal piping vibrations.
-- Selected piping snubbers / restraints were observed for proper fluid level and condition / proper hanger settings.
-- The indicated positions of electrical power supply breakers and selected control board equipment start switches and remote-operated valves and the actual positions of selected manual-operated valves were observed. - -
-- Selected equipment lockout tags, caution tags, and - . .
Do-Not-Operate tags were observed for proper posting and the tagged equipment was observed for proper positioning, where applicable. n ----- --- -- - -- .--
)
9
-- Selected jumper and lifted lead markers were observed for proper identification and the effected wiring changes were observed for proper completion.
-- The Control Board was observed for annunciators that nor-mally should not be lighted during the existing plant conditions. The reasons for the annunciators were discussed with control room operators.
-- The licensee's policy and practice regarding plant tours
- were reviewed.
-- Control Room manning was observed on several occasions during the inspection.
Acceptance criteria for the above items included inspector judgment and requirements of 10 CFR 50.54(k), Regulatory Guide 1.114, applicable Technical Specifications, and the following procedures.
-- SAP 1002, " Rules for the Protection of Employees Working on Electrical and Mechanical Apparatus," Revision 13.
-- SAP 1003, " Radiation Protection Manual," Revision 12.
-- SAP 1008, " Good Housekeeping," Revision 4.
-- SAP 1009, " Station Organization and Chain of Command,"
Revision 3.
-- SAP 1028 " Operator at the Controls," Original.
i
-- SAP 1037, " Control of Caution and DN0 Tags," Revision 1.
-- SAP 1034, " Control of Combustible Materials," Original.
! No items of noncompliance were identified.
- 5. ,In-Office Review of Licensee Event Reports (LERs) (Unit 2) -
The LERs listed below were reviewed in the Region I office promptly following receipt to verify that details of the event were clearly reported including the accuracy of the description of cause and the adequacy of corrective action. The LERs were also reviewed to deter-mine whether further information was required from the licensee, whether generic implications were involved, whether the event should be classified as an Abnorum1 Occurrence, whether the information involved with the event should be submitted to Licensing Boards, and i whether the event warranted onsite followup, i
i 10 The following LERs were reviewed.
-- LER 78-60/3L, dated October 13,1978 (R.B. pressure switch BS-PS-3987 was .01 psig greater than the allowable setpoint of 3.60 psig, due to setpoint drift)
LER 78-61/3L, dated November 1,1978 (while performing pseudo dropped '.ed test, the nuclear overpower trip setpoint was not ver',fied within 8 hours prior to using special test exception of Technical Specifications)
*-- LEP. 78-62/1T, dated October 19,1978 (Technical Specification limit for RCS unidentified leakage was exceeded without shut-down of unit due to misinterpretation of Technical Specification requirements)
*-- LER 78-63/3L, dated November 28,1978 (ratchet trip of Group ,
5 control rods during norral shutdown due to incorrectly installed vendor-supplied field change in three gate drive modules)
-- LER 78-64/3L, dated December 4,1978 (during a calibration check of the BWST level switches, the switches exceeded the setpoint allowed by Technical Specifications)
*-- LER 78-66/3L dated November 15, 1978 (while in Mode 3 the C.R.D. trip breakers were closed on three occasions with only one source range detector oierable)
*-- LER 78-67/3L, dated December 11,1978 (during load service testing, fuses blew in battery chargers 2-2A and 2-2B due to defective gating and filter modules, which resulted in loss of the chargers for Battery Bank B)
*-- LER 78-68/3L, dated December 13,1978 (twelve diesel generator load sequence setpoints were outside the Technical Specification tolerance due to setpoint drift)
*-- LER 78-70/3L, dated December 28,1978 (intermediate range neutron flux and rate functional surveillance was not perforned during heatup prior to closing C.R.D. breakers, due to procedural inadequacy) t
- denotes those LERs selected lor onsite followup
O 9 1 11
*-- LER 78-71/lT, dated December 21, 1978 (make-up pump control logic allowed starting of two pumps from a single diesel generator, due to design deficiency)
-- LER 78-72/3L, dated January 2, 1979 (four R.B. isolation valves failed to close during surveillance testing, due to an inoperable logic relay)
**-- NPDES Pennit 0009920 Noncompliance Notifications 78-22, 78-23, and 78-25 (IWFS discharge of pH limits exceeded)
**-- NPDES Permit 0009920 IWTS Bypass Notification, dated November 3, 1978 The above LERs were closed based on satisfactory review in the Region I office, except those LERs selected for onsite follokup.
- 6. Cnsite Licensee Event Followup (Unit 2)
For those LERs selected for onsite followup (denoted in paragraph 5), the inspector verified that the reporting requirements of Technical Specifications and GP 4703 (Original) had been mat, that appropriate corrective action has been taken, that the event was reviewed by the licensee as required by Technical Specifications, and that continued operation of the facility was conducted in conformance with Technical Specification limits. The inspector's findings regarding these licensee events were acceptable, unless otherwise noted below.
-- LER 78-67/3L described the inoperability of Battery Chargers 2-2A and 2-28, due to blown fuses which occurred during load service testing surveillance. Two defective gating and filter modules were identified and replaced. The licensee will evaluate the need for additional corrective action, pending review of the vendor's examination results of the defective modules. This item is unresolved, pending NRC review of additional lic?nsee corrective actions (320/79-01-01).
-- LER 78-68/3L described the out-of-specification condition of 12 diesel generator load sequence timers, attributed to possible setpoint drift. Future corrective action to prevent recurrence is still being investigated by the licensee, as tracked by PAI 2-78-057. This item is unresolved, pending NRC review of additional licensee corrective action (320/79-01-02).
- denotes those LERs selected for onsite followup
** denoted those environmental reports subject to generic and selective onsite followup during a subsequent environmental inspection
*e ,
e i 12
. 7. In-Office Review of Periodic Reports 1
The periodic reports listed below were reviewed in the Region I office to verify that the report included information required to ) be reported and that test results and/or supporting information , discussed in the report were consistent with design predictions : and performance specifications, as applicable. The reports were also reviewed to ascertain whether planned corrective action was adequate for resolution of identified problems, where applicable, and to determine whether any information contained in the report should be classified as an Abnormal Occurrence. The following TMI-2 periodic reports were reviewed.
-- October Operating Report, dated November 15, 1978
-- November Operating Report, dated December 15, 1978 The above reports were closed based on satisfactory review at the Region I office.
- 8. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items disclosed durinn '
this inspection are discussed in Paragraphs 3 and 6.
- 9. Exit Interviews The inspector met with the licensee representatives (denoted in Para-graph 1) at the conclusion of the inspection on January 10 and 11, 1979. The inspector summarized the purpose and scope of the inspec-tion and the findings.
9
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POST OFFICE BOX 542 READING, PENNSYLVANI A 19603 TELEPHONE 215 - 929-3601 November 1, 1978 GQL 1790 Mr. B. H. Grier, Director Office of Inspection and Enforcement Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Sir:
Three Mile Island Nuclear Station, Unit 2 (TMI-2) p Operating License No. DPR-73 Docket No. 50-320 In accordance with Section 6.91.8.b of our Technical Specification (T.S.) attached is Licensee Event Report (LER) 78-62/lT. This event concerns acti3n b of T.S. 3.h.6.2 pertaining to unidentified leakage in excess of allovable T.S. limits. Sincerely,
/l I
J. G. Herbein
/ Vice President-Generation JGH:RAL:ejg Attachmentti m- u..e 1
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#27 Cause Description and Corrective Actions - Cont'd limits at 0735 on 10-18-78.
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(th NARRATIVE TO LER 78-62/1T At 1000 hours on October 19, 1978, while performing Surveillance Procedure 2301-3D1, it was determined that data obtained subsequent to the last recorded acceptable surveillance performance at 1935 on 10-16-78 showed that unidentified leakage during the interim period exceeded the limits specified in the Technical Specifications (T.S. 3.4.6.2) and that the required action statement was not invoked. The largest unidentified leakage during this period was 2.6 gpm. This event was caus2d by misinterpretation of the requirements of the T.S. Since the actual frequency of performance of the surveillance procedure was greater than that required by the T.S., it was not clear to the personnel involved as to which set of data taken came within the T.S. requirements and when the time requirements of the action statement were applicable. However, action was being taken to reduce the unidentified leakage to within allowable limits and was accomplished at 0735 on 10-18-78, by determining a portion of this leakage to be identifed leakage from the Reactor Coolant System and to be well within the limits of T.S. 3.4.6.2.c. In addition, it was discovered that errors in inputing data to the computer caused indicated unidentified leakage to be greater than actually was occurring. The appropriate personnel will be instructed on the requirements of the applicable sections of the T.S. and the requirement to immediately invoke applicable action eptatements when the provisions of the LCO's are not met. Ique data for the computer program which calculates unidentified leakage hW also been clarified. *
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" Exhibit G
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sc5 Inventory PORC and Facility lianagement Actions , i The inspector reviewed the actions'ta,ker$ by the Plant Operations Review Conuittee (PORC) and facility management concerning previous excessive Reactor Coolant Systeu leakage. The review included discussions with
- Operation Department supervisors and review of the following licensee r:: cords:
-- liinutes of Unit #2 Operations Review Committee Meeting #290, conducted during October 17,18,19 and 20,1978.
i
-- Minutes of Unit #2 Operations Review Comittee Meeting #292, conducted during October 30 and 31, and November 1, 2, and 3,1978.
I -- Hinutes of Unit #2 Operations Review Committee Meeting #79-10, conducted during March S 7, 8 and 9, 1979.
-- Met-Ed letter to NRC Region I dated October 19, 1978 Reportable Occurrence No. 78-62/IP.
3
-- Licensee Event Report 50-320/78-62/0lT dated November 1,1978; Failure to comply with Technical Specification 3.4.6.2 Action Statement b, when unidentified Reactor Coolant System leakage exceeded the 1 gpm limit.
1
-- PORC Action #2-73-053 Tne narrative attached to LER 78-62/IT stated: ,
"At 1000 hrs. on Oct. 19, 1978, while performing Surveillance Procedure 2301-3D1 it was determined that data obtained subsequent i to the last recorded acceptable surveillance performance at 1935 on i
10-Iti-78 showed that unidentified leakage during the interim period
; exceeded the limits specified in Technical Specification (T.S.) 3.4.6.2 and that the required action statement was not invoked. The largest unidentified leakage during this period was 2.6 gpm. This event was caused by misinterpertation of the requirements of the Technical Specifications. Since the actual frequency of performance l
of the surveillance procedure was greater than that required by the ! Technical Specifications, it was not clear to the personnel involved l as to which set of data taken came within the T.S requirements and when the time requirements of the action statement were applicable. However, action was being taken to reduce the unidentified leakage to within allowable limits and this was accomplished at 0735 on October 18, 1978. In addition, it was t discovered that errors in inputting data.to computer caused 5ndic~ated unidentified leakage to -
> - be greater than actually was ocicdrring. The appropriate personnel.
i
-will be instructed on the requirements of .the.).pplicable sectionsof g- - '
the T.S. and the_requirementsito iinmediately invoke applicable - action statements when the prov. i sions of limiting conditions for - r_ r operation are not met. -Input.. data for the computer. program which i
- calculates unidentified leakage has also been clarified." -
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The PORC review and licensee management reporting of the above RCS leakage was perforued as required by Technical Specifications. The corrective actions were appropriate to correct the cause of the occurrence, h: wever, they were not aggressively pursue _d. PORC Action Iten #2-78-053 required the Unit 2 Operations Enginegr to insure the following is documented by ups review of LER 76-62/lP(IT): :"The appropriate personnel will be instructed on the requirements of the applicable sections for the T.S. and the requirement to innediately invoke applicable action statements wnen the provisions of the LC0's are not met." The action iteu due date was designated as 11-20-78 by the Unit 2 Superintendent - Technical Support. Tna original duc date Jias hot met and was extended to 12-15-78 by the PORC Chairman. The reason for the extension was stated to be, "...Due to plant problems and test program this item has been overshadowed. This item will be completed no later than 12-15-78." L The do ment review form used to indicate review of LER 70-62 was initic d by all appropriate Operations Department personnel including shift supervisors, shift foreman and control room operators. liowever, th:re was no indication of when these reviews were actually performed.
'i .~.,..a _nti' : 7 5 PAI #2-78-053 was sianed by the PORC w 3 #-M.
Chairman indicating all action was completedf f " - " ' (4here were no regulatory requirements or licensee comnitments for tompleting the corrective action for LER 78-62 within a specified period.) M e i
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METROPOLITAN EDISON COMPANY --
,f ,
'DIREE MILE ISLAND NUCLEAR STATION
- UNIT #2 OPERATIONS REVIEW CCF44I'ITEE
- MEETING #290 _
October 17, 18, 19 and 20, 1978 I. Mrtinos 4 D1te Time _ Members Items _ Discussed 10/17 0900-0930 (p) R. P. Warren (V-C) PORC Items 1345-1415 (p) R. W. Bensel Tests and Experiments (p) M. L. Denson
* (p) I. D. Porter
* (a) T. E. Marck -
* (a) ' E. D. Showalter
* (a) D. B. Jenkins
* (a) J. A. Brumer
* (a) J. R. Paules
- M. B. Bezilla
- D. Haverkamp (USNRC) ,
10/18 1530-1700 (p) J. L. Seelinger (C) EORC Items (p) R. P. Warren (V-C) Plant itxiifications (p) I. D. Porter ~ Reportable Occurrenc.s/ I (p) R. W. Bensel Violations
,i ,
(p) M. L. Benson i -
* (a) T. E. Marck M. B. Bezilla h
- 10/19 1300-1330 (p) J. L. Seelinger (C) PORC Items 1700-1730 (p) R. P. Warren (V-C) Reportable Occurrences /
* (p) I. D. Porter Violations
,,')i- * (p) J. R. Floyd Other
* (p) R. W. Densel l, " - * (p) R. W. Dubici *
/
(a) W. J. thrshall (a) T. L. Mullcavy
- M. B. Bezilla 10/20 1430-1600 (p) R. P. Warren (V-C) PORC Itens -
(p) I. D. Porter (p) R. W. Bensel (a) T. E. tbrck (a) J. R. Paules M. B. Bezilla NOTES: (C) Chairman (V-C) Vice-Chairnnn (p) Prirrary Unit 2 PORC thmber (a)' Alternate Dnit 2 PORC tenber as designated by ] the_Qiairm'Ir) or Vico-Chairman for this necting. j
~~ ~~~
*(*) Indicates Part-Tinn A_ttendance --
7- . - - - -
'~
The requirenunts of Technical Specifbations 6.5.1.3 j @ ~ and 6.5.1.5 were satisfied at all timas.
'I1n FORC not. formily for a total of 5.0 hours during the week of Octobar 16, 1978
rage a p '.' r _ ' Vceting #290 -~ _ p# , October 17, 18, 19 and f;- * * . 20, 1978 g III. Tests and Experinents
'Ibst Procedures _
- 1. The following Test /Special Procedure " Partial 'Ibst Results", 40% Plateau, were reviewed and recumended for approval:
Test /Special Procedures _
'IP211/1
'IP271/4 (Rctest)
TP500/3 TP800/7 TP800/14
'IP800/23 SP800/8 .
SP800/21 IV. Tech Specs /Licensina Items _ Nono V. Plant Modifications Change iblification 2-0140 was reviewed and the PORC has determined nirthernere, that this- 04this
' 04 does not constitute any unreviewd safety questions, "]~ was reccnnended for Unit Superintendent approval.
VI. Rcrortable occurrences / Violations im-P-2A Shaft Pailure (Sco Attaclimnt Onc)
@ 78-62/IP(1T) (Pailure To Invoke The Im, action b, of T.S. 3.4.6.2)
NRC has reviewed this incident and determined it to be prmpt reportIble y inaccordince with T.S. 6.9.1. 8.b. (.% Attacinent '140) VII. Pinnt Orcrations. . Various ncmbers of the PORC attended the POD where plant op2 rations were reviewed, discussed and evaluated. Various numbers of the mRC also aided and assisted in recomiending future activitics to the Unit Superintendent.
-- VIII. Sty cial paviews and investfontions f. ._
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.- WW7 Mett:politan Edison Company j? /- -' "-
9,, , [k Post Of fice-Box 480 Middletown. Pennsylvania 17057 ,. 717 944-4041 Y . October 19, 1970 Mr. Boyce H. Grier . Director of Regulatory Operations Regton I ~ "
- Nuclear Regulatory Comission 631 Park Avenue .
King of Prussia, PA 19406 Operating License: OPR-73 Docket: 50-320 .
Subject:
Reportable Occurrence No. 78-62/IP
Dear Mr. Grier:
This telegram is to confirm the conversation between Mr. J.L. Seelinger, Unit 2 Superintendent Technical Support, and Mr. D. Haverkamp, Region I NRC at 1530 hourt on October 19, 1978.
- b. A situation considered reportable under technical specification 6.9.1.8.b ),,. !
was discovered at 1000 hnurs on October 19, 1978, when it was determined that the limiting condition for operation (LCO), action b, for T.S. 3.4.6.2 - was not invoked when surveillance procedure, 2301-3D1, data obtained at
- 1935 on 10-16-78 showed an Unidentified Leakage greater than 1 gpm (2.6 gpm actual unidentified leakage). W This event occurred due to personnel errors in interpreting both the LCO ,
and surveillance performance requirements of T.S. 3.4.6.2. . Unidentified leakage was reduced to T.S. limits at 0735 on 10-18-78.
- Further details and corrective action will be discussed in the followup report.
J.L. Seelinger -
-. Unit 2 Superintendent / ..
Technical Support - JLS:bil . . 3 1
._ __ 1, ,
b- _._ . Metropo!itan Edson Company es a Member of the Generat Pubic UStocs System --
- ~
McITOPOLITid EDISON CQ4PANY
'nftEE MILE ISLND NUCLEAR STATION
** "~
. UNIT #2 OPERATIONS REVIEW CCIMrITEE
~
MEEr1NG H292 October 30 and 31 and November 1, 2 and 3, 1978 (o) I. Feetinas _ Date Tirre bers Items Disc ssed 10/30 1730-1800 (p) J. L. Seelinger (C) Reportable Occurrences / (p) R. P. Warren (V-C) Violations (p) R. W. Bensel ~ (a) W. J.Lels (a) T. E. Marck 10/31 1300-1330 * (p) J. L. Seelinger (C) PORC Items 1800-1830 (p) R. P. Warren (V-C) Ennrgency Plan /Procedur (p) R. W. Densel
* (p) I. D. Porter
* (a) T. E. Marck
* (a) M. L. Ben. con
* (a) J. A. Brumer 11/1 0900-0930 (p) J. L. Seelinger (C) PORC Itcrs (p) R. P. Warren (V-C)
(p) I. D. Porter (a) D. B. Jenkins (a) T. E. Perck g 11/2 1630-1730 2200-2230 (p) J. L. Seelinger (C) (p) J. F. Hilbish (V-C) FORC Items Tech Specs / Licensing It (p) R. W. Dubiel Plant f kxlifications
* (p) R. E. Sieglitz Reportable Occurrences / '
* (p) R. P. Warren Violations
* (p) J. R. Floyd Security Plan / Procedure-
* (p) I. D. Porter Dmrgency Plan /Procedur
* (a) D. B. Jenkins M. B. Bezilla 11/3 1530-1615 (p) J. F. Hilbish (V-C) PORC Items (p) I. D. Porter Plant ledifications (p) R. W. Bensel (a) T. E. Ibrck (a) J. D. Lawton M. B. Bezilla NCTIES: (C) Chaianan (V-C) Vice-Chairman (p) Primary Unit 2 PORC M3mber
._ [a) Alternatej nit U 2 PORC Member as designated by the Chairgen or Vice-Chainmn for tlus meetlng.
- -_ t ,
___ f, * ) . -Indicates Part-Tim Attendance
.__ = __
The requireisu.s of Technical Specificati ons-63 .1.3 g_ ]
~
&nd 6.5.1.5 were satisfied at all tines.
~
The PORC met formally f5r af total of 4.25 hours during the week of October 30,
~
1978. j e
o i Page 3
~
Neting #292 October 30 and 31 and Novenber 1, 2 and 3, 197i e V. Plant Modifications
#220137, #2-0157, #2-0172, #2-0179, #2-0189 and Change
#2-0201 Modifications were reviewed#2-0104',,PORC and the has determined that none of there cms constitute an unreviewed safety question. Furthernere, the PORC rec.nms=.rds these m s for Unit Superintendent approval.
" ~
VI. Reportable Occurrences / Violations PORC Review of NCR 78-171 (Rinctional Fire Barriers) (See Attachicnt '1%o) LER 78-61/3L (Fhilure To Satisfy The Requirennnts For Usino The Special Test Exception Of T.S. 3.10.1) PORC has reviewed and concurs with the response being forwarded to M32A inregard to LEr.78-61/3L. (See Attachnunt Three) bLER 78-62/IP(lT) (Failure To Invoke The IID, action b, of T.S. 3.4.6.2) PORC has reviewed and concurs with the response being forwarded to M32A inregard to LER 78-62/lP(IT) . (Sce Attachnent Four) ; VII. Plant Operations Various nembers of the PORC attended the FOD where plant operations were reviewed, discussed and evaluated. Various members of the PORC also aided and assisted in reccrmending future activities to the Unit Superintendent. VIII. Special Reviews and Investications None IX. Security Plan / Procedures Procedure Chance Recuests
- 1. The following Prtx:edure Change Request was reviewed and recommnded for Unit Superintendent approval:
PCRs 78-789 C _
~
X. Ennroency Plan / Procedures [ ,
..4 , _
_ Procedure _ Chance Requests 2 E -. . l.. -
- 1. The following Procedurs Cliangb Requests were revieed and reccmm_nded for -
.g Unit Superintendent-approval: 7 -
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'$ METROPOLITAN EDISON CCMPANY
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POST OFFICE BOX 480 MIDD LETOWN. PENNSYLVANIA 17C57 'T ELEP HON E 717-944-4041 i T0: MR. G.J. TROFFER
SUBJECT:
UNIT 2 LICEf!SEE EVENT REPORT 7n_ofiT.
- 1. Subject report is forwarded.
I h 'phg Vic h J.L. Seelinger PORC Chairman THI-2 JLS:bli . _ cc: J.J. Barton R.M. Klingaman J.P. O'Hanlon 11.B. Barilla G.A. Kunderr D.M. Shovlin R.W. Dubiei / L.L. Lawyer Control Roon Unit 2 J.P. Floyd J.B. Logan GRC Secretary J.G. Herbein T.A. Mackey Office File J.F. Hilbish a G.P. Miller Training Department Preparer James R. Stair I f *
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LICENSEE EVENT REPORT CONTROL stock: 1 I l 1 l ~l l (PtEasE PRINT OR TYPE ALL REQUIREO ins WATIONI I . i e@. olllPlAlTl MIl2lg,60 [ 0 l -l O l 0l 3 g LiggNSEE CCOL 38 LICgwSL 0] Nwusta 0l 0l .-l Ol OQ 2S h26 l 1 l 1 ] 1l 3 jgl 3 6CA1 _LsCENSE Tvrt JO l helg e
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( mepomT 0111 oaft rl j s to e5 Doca ET Nuwegn es C J l EVENT DESCRIPTION AND Pr.o8 AsLE CONSEOuENCES I u g a l lDuring performance of surveillance procedure 2'301-3D1 on Octobe- 1o ,evg 4+ v,, , i E laeterained that the liEiting condition for overation (LCol . action b fe, me,.h %,. I o I A I 1(T.S.) 3.h.6.2 was not invoked when surveillance n' eean n, . s m a m a... ,m .4 D l l o I s 1. lat _1935 on 10-16-78 shoved unidentified leakP.re r-ente
- thaa 7 r-'a (> #M =r =7 I l
o 16 I luni deat4 *4 pa l e.ka rel ~ Cina. all 7makne. + . . . - . + b. W r*C += p .w = . E th cuaM the c+ A 4vq ,r+ .fr.g+ + . h.7th and an ,+v'. e.f tWe I ol7))v A,.r,=+, +-,+-,n+ f g + .-, +w4w. m I 10l4l lnnh14e. so 7 ee sysTtu CAust CAust Coup. VALvt
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SEOuttettAL OCCUR 8E8eCE REPo47 afvtsaces
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k ATT ACMuG NT esemo a PaswtCDup Cou o*=8'e t ACTeoes Futunt . EpptCT suutooseN pomu sue. sumpsit e . WA* ue'ACTL-me se ) .f, ossPLANT utTwoo wouns . sysueTTto
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$;@ l Verformance for the surveillance above that reeuf--! W *S.* * ' '
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.N tha ".*. f h I clear to personnel involved as to which set of datI taken cR .e hthf r:
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i NRC USE ONLY _. eS5uto DESCme*Ttose Q l llfIIIl111111 21 o1 L Yj@lWeekly News Release , % ss es 40
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( __ 3 l t. g Licensee Drent Report -
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#27 Cause Descrivtion and Corrective Actions - Cont'd limits at 0735 en 10-18-78. ,
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, NARRATIVE TO LER 78-62/1T -
At 1000 hoors on 0:tober 19, 1978,4 while performing Surveillance Procedure , 2301-3DI, it was detemined that data obtained subsequent to the last i recorded acceptable surveillance performance at 1935 on 10-16-78 showed tha't unidentified leakage during the interim period exceeded the limits specified in the Technical Specifications (T.S. 3.4.6.2) and- that the required action statement was not invoked. The largest unidentified leakage during this period was 2.6 spm. [ This event was caused by misinterpretation of the requirements of the T.S. Since the actual frequency of performance of the surveillance procedure was o greater than that required by the T.S., it was not clear to the personnel
- involved as to which set of data taken came within the T.S. requirements and when the time requirements df the action statement -vere applicable.
However, action was being taken to reduce the unidentified leakage to within allowable limits and was accomplished at 0735 on 10-18-78, by determi2ing a p'ortion of this leakage to be identifed leakage from the Reactor Coolant System g and to be well within the limits of T.S. 3.4.6.2.c. In addition, it was discovered that errors in inputing data to the computer caused indicated
#* unidentitiec Aeakage to be crescer v 5um acenally was occurring.
(.; The appropriate personnel vill be instructed on the requirements of the l g 3,
- applicable sections of the T.S. and the requirement to immediately invoke
?. applicable action statements when the provisions of the LCO's are not met.
f,' Input data for the _ computer program which calculates unidentified leakane - b has also been clarified. "
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mLITAN EDISON NM
'IHREE MILE ISLAND NUCLEAR STATION UNI.' #2 OPERATICNS REVIDf CCIHITTEE PEETING #79-10 -
1 burch 5, 7, 8 and 9, 1979 I l I. feetinas 4 Date Time Bent)ers Items Discussed l l 3/5 1030 '1.30 * (p) G. A. Kunder (C) PORC Items l 1500-lw0 (p) R. P. Warren (V-C) ICRC Action Items l (p) 'R. '1. Bensel
*(p) I. D. Porter I (a) J. D. Lawton (a) D. B. Jenkins
*(a) D. L. Good
- M. B. Bezilla 3/7 1030-1100 (p) R. P. Warren (V-C) PCRC Items (p) I. D. Porter (p) R. W. Bensel (a) T. E. !brck (a) D. B. Jenkins 3/8 1315-1500 (p) G. A. Kunder (C) PORC Items (p) R. P. Warren (V-C) Tech Specs / Licensing Items (p) I. D. Porter (a) T. E. terck (a) J. R. Paules
-
- M. B. Bezilla 3
3/9 0930-1030 (p) G. A. Kunder (C) PORC Items (p) I. D. Porter (V-C) Reportable Occurrences / (p) R. P. Warren Violations (a) T. E. Morck PORC Action Items
~ (a) T. A. O'Ccnner M. B. Bezilla NOTES: (C) Chairman (V-C) Vice-Chairman (p) Primary Unit 2 PORC Msnber (a) Alternate Unit 2 PCRC Ment]er as designated by
- the Chairman or Vice-Chairman for this meeting.
(*) Indicates Part-Tima Attendance
'Ibe reqturements of Technical Specificaticns 6.5.1.3 and 6.5.1.5 were satisfied at all times. -
'Ihe PCRC net formally for a total of 5. 25 hours during the week of March 5, 1979.
==.- ,
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. Page 3
, . meting #79-10 March 5, 7, 8 and 9, 1979 VI. Reportable Occurrences / Violations IORC Review Of NCR~78-179 For Reportability 4
(See Attach ent h) LER 79-012/3L (Decradation Of Fire ' Barrier ' Penetrations Constructed Of Firewall - 50 PORC has reviewed this item and d 'etermined that it constitutes a thirty day report inaccordance with T.S. 6.9.1.9.b. (See Attachnent '1hree)
~
VII, Plant Ocerations Various me:rbers of the PCRC attended the POD where plant operatitxis were reviewed, discussed and evaluated. Various merrbers of the PORC also aided and assisted in rec.ummuding future activities to the Unit Superintendent. VIII, Special Reviews and Investications None IX. Fecurity Plan / Procedures None X. Breraency Plan / Procedures (- None XI. PORC Action Items
'Ihe following PORC Action Items were reviewed and considered closed by the PORC:
PAI 2-78-053 PAI 2-78-056 . PAI 2-79-006 PAI 2-79-019 (2-79-014 also) PAT 2-79-021 , PAI 2-79-022 (See AttachTent Four) , XII. Other
- 1. PORC reviewed all of the items covered'in Secticos II through VI and IX and X and concl*: that none of the' items constituted an Unreviewed Safety
[ - Question, ! -j ._
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1 ~ , . Sarial # RAI 2-78 053 - s Responsible Individual: W. Marshall
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W. Fels { _ TMI-2 P0kCACTIONITEMS ..
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I. -Item Responsible for Initiating PAI:
- a. Licensee Event Report 78-62/IP (IT)
- b. NRC Inspection Report # Page
- c. IE Circular . .
d IE Bulletin -
- e. Other .
I Title /
Description:
II. Failure To Invoke T.S. 3.4.6.2 (RCS Leakage Spec) III. Commitmbnts/ Action Required:
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WJM - Insure the followii.:) is documented by Ops review of LER 78-62/IP (IT):
"The appropriate personne1 will be instructed on the requirements of the applicable sections for the T.'S. and':the reqdiremehtito innsdiatily'invMe' de[efe pa applicable action statements when the provisions of the LCO's are not met."
J/$ . WJF--Shor-t-wr-iteup er the felleAg-j _ _ _ . arnnip ria+n Snr + he _. .. .. .u t e r aragre= ' Aich calculate uridenti# icd lc:kage. A _ . . has_a.lso been-ebe"ied." . Due Date: 11-20-78 ( JZd" IV. Documentation of Completion (Procedure Revised, PCR!, T #, WR Number, tc.) (Attachments as necessary) .
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'See attached signed-off sheet. '
All Action Completed [ -
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hff 87 '1.6VL. i 3 f 0-7 t PORC-{hairman31-2 - Date - d ._ Z !
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cc: Station Superintendent- . Unit 2 Superintendent . M. B. Bezilla -
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Res;ionsible Individual
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THI-2 PORC ACTION ITEM . 4 PAI # 2 C d Due Date: //-E#- New Due Date: #2-if- 73 . Reason for Extension: 7 m
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!( Submitted By:
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Concurred: ,
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P(RCChairman - TMI-2 r o
. Distributi'on: H. B.'Bezilla - -
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Responsible Person (w461) -
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. DOCUMENT REVIEW g UNIT #2 CONTROL R00:1 .
REVIEW BY //O / ~78 ' DOCUMENT N0. 468 ~78-la 2. REVISION NO. 6 DOCUMENT TITLE M /E4c466 SHIFT SUPERVISORS I ilY '/ W.H. Zewe . I fu J. R. Floyd . / J.J. Chwastyk ./ W. J. 3tarshall LK/ g K.P.' Bryan /.fM / - G.R. Hitz fAlt
'B.G. Smith WW.
{] B.A. Mehler sea- . fv h 1\..tcast e,s - [( _ SHIFT FORE:4EN . A.W. Miller M C.D. Adams e-A .e. R4. Hutchison --- K.R. Hoyt u H. -
- c. L. C.:w,, gyi W.T. Conaway C3M F.J. Scheimann S Lt -
4 . CR0'S
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E.R. Frederick b' L.0. Wright W '
.C.C. Faust /71,#T M.S. Coleman M / L-H.A. McGovern .,W D.I. Olson .l#(J -
T.F. Illjes @ t - R.R. Booher _ 93 E.D. Hecunila 4 40' L H.W. Hartman : 1k , _ _ . C.F. Hell ~ l }fW: J.M.~ kidWell -ffW7
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J.R. Congdon /TE W- - H D. Phillippe: I
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M.V _ Cooper 7 % ', -- L.P. Germer - n. _
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