ML20214P485
| ML20214P485 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/03/1986 |
| From: | Blough A, Conte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20214P480 | List: |
| References | |
| 50-289-86-12, NUDOCS 8609230119 | |
| Download: ML20214P485 (19) | |
See also: IR 05000289/1986012
Text
, .
.
.a
.
, . -
.
- ..
e
'U.S. NUCLEAR REGULATORY COMMISSION-
REGION I
Report No.
50-289/86-12
. Docket No.
5'0-289
-
License No.
Priority --
Category C
Licensee:
GPU Nuclear Corporation
Post Office Box 480
Middletown, Pennsylvania 17057~
Facility At:
Three Mile Island Nuclear Stetion, Unit 1
. Inspection At:
Middletown, Pennsylvania
Inspection Conducted:
July 7 - 11 and August-14, 1986
Inspectors:
W. Baunack, Project Engineer
R. Conte, Senior Resident Inspector (TMI-1)
Reporting Inspector:
M
'7-Mcf(
f
R. Conte,' Senior- Resident- Inspector (TMI-1)
Date
Approved By:
7-3-d
'
A. BlostJh, Chief
Date
Reactor Projects Section No. IA
Division of Reactor Projects
Inspection Summary:
This was a special safety inspection based primarily on the performance
Appraisal Team findings (NRC Inspection Report No. 50-289/86-03).
It involved
54 inspection hours. Additional limited inspections of the licensee's modifi-
cation control procedures were' conducted to identify more specifically the
licensee procedures that implement NRC requirements applicable to PAT findings.
Inspection Results:
Four-violations, each with multiple examples, were identified. The four
applicable NRC requirements were for:
the conduct of safety evaluations in
accordance with 10 CFR 50.59 (paragraph 2); proper implementation of design
control requirements in accordance with ANSI 45.2.11-1974 (paragraph 3); proper
implementation modification control instructions / procedures (paragraphs 4 and
5); and, prompt corrective action on known conditions adverse to quality
(paragraph 6),
h
G
.
_.
-
-
.
.-
.
. . _ . . ._ .
. _- . _
.
.
.
.
2
,
.
J
Based on the modification control problems noted, NRC concerns were raised on
the adequacy of other modifications that have been developed under the same
licensee process, such as the emergency feedwater system modifications to be
installed in the upcoming refueling outage. This will require additional
licensee and NRC review prior to Cycle 6 startup, scheduled for April 1,1987.
l
,
4
i
f
&
.
$
t
.
.
1
i
i
!
.
k
5
--
- . , , - - , . -
,,,,,,,,-..,,_---n,
n.--,-
n,,.
.7m.-,.,
- , , , - . , . , - . ,,__.-
,,,-.w..r.
_,.
,,_
,
.-_-.,----_n
= _ , - ,
- _ _ - _ - _ - _
-
.
-
,.
.
4
DETAILS
- 1.
Introduction and Overview
i
The purpose of this inspection was to review the NRC Performance
Appraisal Team (PAT) inspection (Report No. 50-289/86-03) findings to
(1) determine which findings were examples of violations of NRC
requirements, and (2) itemize and, in some cases, clarify other items
requiring additional followup. The basis for this review was primarily
the objective findings of the PAT inspection as documented in the subject
report. However, a limited review of licensee procedures was conducted to
i
further identify procedures that implement the applicable NRC requirements.-
'
.The findings of PAT were grouped into four categories:
acceptable
items or positive comments for information only; unresolved items
(defined in paragraph 10); inspector follow items (defined in paragraph
10); and, other' findings not specifically numbered. The latter three
categories were independently reviewed by the Region I inspectors to
identify violations of NRC requirements. By its purpose, this inspection
necessarily focuses on the negative aspects of PAT findings and does not
revisit the positive findings.
.This report dispositions most of the PAT findings; these dispositions are
summarized in Attachment I to this report. Also, certain PAT observations
(not specifically numbered in the PAT report) were considered by Region I ,
to be issues warranting additional information to determine acceptability.
Accordingly, these are identified in this report as new unresolved items.
Certain PAT unresolved items involve multiple issues; these individual
issues are redesignated by this report to facilitate individual followup.
Some PAT findings retained their status (and numbering) since this review
identified no new information to update the items; these items also are
evident in Attachment 1.
2.
Safety Evaluation Implementation
i
2.1 Introduction
The Performance Appraisal Team (PAT) inspection identified a number
of examples in which design change safety evaluations were not
thorough enough to assure proper implementation of safety grade
criteria as reflected in the updated safety analysis report (SAR).
The 10 CFR 50.59(b) requires, in part, the licensee to perform a
written safety evaluation to assure that changes in the facility as
described in the SAR do not involve an unreviewed safety question
(defined by 10 CFR 50.59a(2)). To implement this requirement, the
licensee has Technical Functions (TF) Engineering Procedure
(EP)-016. Revision 1-00, dated January 18, 1985, " Nuclear Safety /
Environmental Impact Evaluation." In Exhibit 3, EP-016, paragraph
3.3 requires, in part, that the written safety evaluation for
facility changes describe how the proposed change will or will not
_ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _
'
.
-
, . .
4
...
,
.
affect the. safety function (10 CFR 50 Appendix A Criterion 34) by
addressing: system. performance (paragraph 3.3.1); natural phenomena
with respect to seismic classification (paragraph 3.3.3);. electrical
isolation criteria (paragraph 3.3.9); and, single failure criteria
(paragraph 3.3.11). Specific examples of ifcensee failure to meet
these requirements from the PAT report are addressed in paragraphs
2.2, 2.3, and 2.5 below.
The 10 CFR 50.59(b) also requires that a similar review be completed
for change to procedures as addressed in SAR. To implement this
requirement, the licensee has Administrative Procedure (AP) 1001A,
Revision 10, dated April 17, 1986, " Procedure Review and Approval."
Figure AP 1001A-5, paragraph'2, implements that' requirement to
identify whether or not a procedure change constitutes an unreviewed
safety question. A specific example of licensee failure to meet
these requirements is addressed in paragraph 2.5 below.
2.2 (Closed) Unresolved Item 289/86-03-09):
Inadequate Control
of lead shielding installation.
Paragraph III.A.3.a (1) of the PAT report identified that lead
shielding was installed on important to safety systems without a 10 CFR 50.59 evaluation.
Further, the technical evaluations for
installed lead shielding did not fully address piping system perfor-
mance under dynamic loads along with assuring adequate protection for
a seismic event. This failure to fully evaluate the installation of
lead shielding is example of apparent violation of 10 CFR 50.59(b)
,
and EP-016, Exhibit 3, paragraphs 3.3.1 and 3.3.3.
2.3. (Closed) Unresolved Item 289/86-03-01: Two-Hour Backup Instrument ~
Air System did not meet safety grade single failure criteria.
Paragraph III.A.1.a of the PAT report described a design basis
single failure susceptibility of the Two-Hour Backup Instrument Air
(TBIA) sub-system for the Emergency Feedwater (EFW) system at supply
i
lines for MS-V-6, pressure regulator for the inlet to the turbine-
driven EFW pump. The TBIA was a safety grade restart modification.
Although the licensee completed a 10 CFR 50.59 evaluation, licensee
personnel did not identify the single failure susceptibility until
identified by PAT inspectors. Accordingly, this failure to identify
the single failure susceptibility of the EFW TBIA is another example
of an apparent violation of 10 CFR 50.59 and EP-016, Exhibit 3, para-
graph 3.3.11.
Licensee immediate corrective actions were to report the item in
accordance with 10 CFR 50.72 and 50.73 (See Licensee Event Report
86-07), along with shutting IA-V1450 and IA-V1459 manual isolation
valves upstream of the subject check valves to preclude the single
failure susceptibility.
.
-
..
5
-.
.
2.4 (Closed) Unresolved Item 289/86-03-06: _ Remote Shutdown Panel EFW
Instrumentation not electrically isolated from control room panels.
Paragraph III.A.2.b(1) identified that the safety grade steam
generator (digital) level display at the remote shutdown panel (RSP)
was not electrically isolated from the control panels with respect
to power supplies. The PAT report focussed on compliance with 10 CFR 50 Appendix R electrical isolation requirement.. However,
commitments were also made by the licensee for restart (as reflected
in updated SAR section 7.3.2.2.b(8)) that the RSP steam generator
level instrumentation would be (electrically) isolated from control
room panels.
Paragraph III.A.2.b(2) of the PAT report also identified that the
power supply for. safety grade containment water level instrumen-
tation outside the control room location (local panel) were not
electrically isolated from the control room panels. The updated SAR
section 7.3.1.1.c(11)(b) states, in part,'that the containment water
level instrument output signal condition cabinet (and local panels)
are isolated from control room panels.
The electrical isolation findings noted above would be significant
if the control room indicator were not seismically qualified, that-
is, a failure of the indicator due to a seismic event could effect A,'
i.
,
the entire safety grade instrument loop. The licensee reports that
these indicators were seismically qualified. This is unresolved
pending Region I review of the licensee qualification data / analysis
for these instruments.
(289-86-12-17)
,
2.5 (Closed) Unresolved Item 289/86-03-24: Adequacy of EFW pump
surveillance testing.
Paragraph III.D.1.b of the PAT report identi-
fled that the appropriate surveillance test for EFW pump testing was
inconsistent with the applicable section of the SAR. The SAR section
10.8.2.2.f states, in part, that the flow test to demonstrate feeding
the steam generator would be done using normal alignment. However,
surveillance procedure (SP) 1303-11.42, Revision 6, dated June 26,
1986, " Emergency Feedwater Flow Test from Condensate Storage Tank,"
requires ~that respective cross-connect valves, "EF-V2A and B" be
closed during the test which is contrary to the normal alignment of
being open. The revised test lineup precluded the ability of the
test to detect excessive backflow through discharge check valves of
idle EFW Pumps. With excessive backflow, the consequences of a
loss-of-feedwater transient could be worsened.
Apparently, previous safety evaluations did not address the test
alignment inconsistency with the SAR commitment. The failure to
identify this inconsistency is an apparent violation of 10 CFR 50.59(b) and AP 1001A, Figure AP 1001A-5.
Paragraph III.D.1.a of the PAT report also addresses a concern that
the monthly surveillance test of EFW pump (SP 1300-3G A/8, Revision
21) creates an artificial initial condition by operators blowing
I
-
-
..
6
.
.
down steam traps before the test of the turbine-driven pump.
In
their response letter, dated June 27, 1986, to the PAT report, the
licensee indicated that they had performed a test to confirm that the
blowdown was not an artificial condition.
This area remains unre-
solved pending additional Region I review of the licensee's evalua-
tion of the above-noted test data (289/86-12-01).
2.6 Conclusion
The failures (see paragraphs 2.2, 2.3 and 2.5 above) to properly
evaluate facility changes and procedure changes to assure consistency
with SAR commitments (no unreviewed safety question) constitute an
apparent violation of 10 CFR 50.59b.
(289/86-12-02)
3.
Design Control Implementation
3.1
Introduction
During their review of modifications, the PAT inspection identified
certain problems in the areas of adequacy of design inputs, control
of design inputs, implementation of the design verification process,
and post-modification testing.
These problems were, in general,
identified as violations of ANSI N45.2.11 and in some instances
were noted as being contrary to facility procedures.
Specific examples associated with this apparent violation are as
follows.
3.2 Review,-Approval and Basis for Design Input
3.2.1
EFW Air Bottle Sizing
As part of unresolved item 289/86-03-05, the PAT Inspection
Report paragraph III.A.1.e.(1), noted that the calculation
which determined the minimum allowable manifold pressure of
the two-hour backup instrument air system needed to maintain
an adequate stored air capacity was based on inappropriate
system leak tests.
The licensee provided documentation which indicated that
Calculation No. 1101-852-5360-001 dated July 21, 1983 was
based on appropriately reviewed test procedures and test
results (SP 250/3.1, test results reviewed May 12,1983).
This aspect of the item is considered closed.
The PAT inspector apparently was not aware of the May 1983
test and believed the licensee had used November 1982 data
which was unacceptable.
Adequacy of testing is still unresolved, tracked by a
later item (see paragraph 7.2).
.
-
,.
7
.
.
3.2.2
As part of unresolved item 289/86-03-05, the PAT Inspec-
tion Report 50-289/86-03 paragraph,III.A.2.a.(2),noted
a weakness in the design input associated with battery
sizing. The team reviewed the latest sizing calculation
for the new battery to be installed during the March /
April 1986 outage and determined that the battery was
sized based upon a minimum battery temperature of 72 F.
No reference was included in the calculation for the
basis of this minimum temperature. Actual battery tem-
peratures recorded were found to be lower than the 72 F
minimum temperature assumed. The team also found that
other design input data used in the calculation, such as
pump and valve starting and running currents, lacked
sufficient references to permit complete verification of
the calculations. This lack of control of design inputs
is contrary to the requirements of ANSI N45.2.11, paragraph
3.1.
3.2.3
DC Distribution Fuse Sizing
As part of unresolved item 289/86-03-05, the PAT
Inspection Report, paragraph III.A.2.a.(4), noted the use
of prelimir.ary, unverified design input as a basis for fuse
changes in de system power distribution panels. The use of,
preliminary, unverified design input is contrary to the
requirements of ANSI N45.2.11, paragraph 3.1.
3.3 Vendor Design Interface
As part of unresolved item 289/86-03-05, the PAT Inspection Report
paragraph III.A.I.e.(2), noted the design input associated with
sizing of air regulating valves was provided by GPU to an architect
engineer but was subsequently changed by the licensee without
notifying the affected design organization,
i.e., the architect
engineer. This failure to control interfaces between organizations
.
is an example of an apparent violation of ANSI N45.2.11, paragraph
5.1.3.
3.4 Design Verification
3.4.1
(Closed) Unresolved Item 289/86-03-02:
EFW Two-Hour
Backup Instrument Air Modification Testing. The PAT
Inspection Report 50-289/86-03, paragraph III.A.I.c,
discussed problems with the post-modification functional
testing of the two-hour backup supply air system.
The
system is designed to supply bottled air for a minimum of
two hours following the loss of normal and backup instru-
ment air systems. The team found the post-modification
testing was not structured to confirm that the design basis
.-
-
.
- - -
-
-
.
. _ -
--
-
. - _ .
-
_-
.
-
.-
8
.
.
for the system been satisfied.
Specifically, the team
determined the test did not confirm that the system was
adequately sized to supply sufficient air to cycle all
associated valves twenty times as specified in the design
or to observe a minimum of ten strokes per valve as
required by the System Design Description (SDD). The
failure to implement a test procedure, which verified that
the modification was capable to perform its intended func-
tion, is an example of an apparent violation of the
requirements of ANSI N45.2.11, paragraph 6.3, and Techni-
cal Functions Procedure 5000-ADM-7335.01, "Startup and
Test Program and Test Requirements."
3.4.2
(Closed) Unresolved Item 289/86-03-09 (Part): Design
Verification on Lead Shielding. The PAT Inspection Report
50-289/86-03, paragraph III.A.3.a.(4), noted calculations
to support lead shielding installations were not verified
in a timely manner. There had been approximately ten
shielding calculations accomplished and only one had been
verified prior to the installation of the shielding. The
failure to accomplish design verifications prior to the
installation of the design is an example of an apparent
violation of the requirements of ANSI N45.2.11, para-
graph 6.1.
3.4.3
(Closed) Unresolved Item 289/86-03-11): Design
Verification for Various Modifications.
The PAT Inspec-
tion Report 50-289/86-03, paragraphsIII.A.3.c.(1),(2),
and (3), discussed certain deficiencies associated with
the design verification process as follows:
3.4.3.1
III.A.3.c.(1): This paragraph identified three
engineering calculations, Calculation No. 1101X-322F-165 -
Flow Rates for Two-Hour Backup Air Supply System; Calcula-
tion No. 1101X-322F-424-1 - EFW System Resistance; and
Calculation No. 1302X-5320-A50 - Shielding stress, which
had no design verification accomplished.
3.4.3.2
III.A.3.c.(2):
This paragraph identified three design
verifications, Calculation No.1101X-3228-003 - Air
Consumption by EF-V-30 Valves; Calculation No.
1101X-322F-157 - EFW Pump Turbine Relief Valve Setpoint;
and Calculation No.1101X-322B-004 - Air consumption by
MS-V-6, which did not have required verification check-
lists prepared.
3.4.3.3
III.A.3.c.(3): This paragraph identified System Design
Descriptions (SDDs), which had not been design verified.
The SDDs, which were not verified were SDDs 424A, B, C,
D, and E, Division I and II, involving the EFW system,
its backup instrument air supply, and supporting
. -
'
p
r.
.
V
...
[.l1
9-
,
,,
L
F
instrumentation. The team; following a review of an
additional Technical Functions Procedure,.a visit to the
licensee's architect engineer's offices, and discussions
with Itcensee personnel; verified that SDDs were considered
i
design inputs and, as such, required verification.-
3.4.4
The above (paragraphs 3.4.1, 3.4.2,'and'3.4.3) are con-
sidered to be examples of the f,ailure to adhere to the
ANSI N45.2.11 design verification requirements, which are
o
reflected in' Technical Functions Procedure 5000-ADM-
L
7311.02, " Design Verification."
3.5 Conclusion
The above.'noted failures to properly implement ANSI 45.2.11 are
examples of an apparent violation of 10 CFR 50 Appendix B and QAP
Appendix C (289/86-12-03).
The number of items identified raises questions as to whether the
problems are as a result of-procedures associated with facility
modifications not being sufficiently' clear to assure that the
requirements of ANSI N45.2.11 are incorporated in modification
packages or whether or not personnel are attentive to procedural
'
requirements. During the review, the inspector noted that many
Technical Functions procedures do not provide information as to what
sections of ANSI 45.2.11 or other sections of the ANSI 45.2 series
documents were being satisfied by the specific procedure. Thus, the
correlation between ANSI 45.2 series requirements is not always
clear. This area will continue to be reviewed by Region I and is
considered to be unresolved (289/86-12-04).
4.
Minor Modification Program Implementation
4.1
Introduction
During their design change program review, the PAT inspection
evaluated in detail the mini-mod process described in procedure
5000-ADM-7350.05, " Mini-Mods." Also, four specific mini-mods were
reviewed. The four mini-mod work packages were evaluated for
procedure compliance as well as appropriate design change control
requirements.
l
The team found the basic program and control of mini-mods to be
adequate. However, two types of procedural implementation problems
were noted. The first dealt with the failure to recognize that the
modifications affected the FSAR descriptions and the second identi-
fled the failure to address all the attributes which the mini-mod
procedure required to be addressed. These identified procedural
violations indicate that, even though good overall procedures
covering mini-mods have been prepared additional attention is
,
needed to assure that procedures are adhered to.
The specific items
identified are described as follows.
.
.-
10
.-
.
4.2 (Closed) Unresolved 289/86-03-10:
Improper Implementation of the
Minor Modification Program. The PAT Inspection Report 50-289/86-03,
paragraphs III.A.3.b.(1) and (2), documented certain minor modifica-
tion (" Mini-Mod") procedural implementation problems as follows.
4.2.1
III.A.3.b.(1):
This paragraph documented two instances in
which 10 CFR 50.59 evaluations for two mini-mods (addi-
tional limit switches for the fuel handling crane and
removal of instrument air lines for EFW pumps recircula-
tion valves) were incorrectly marked as no change being
required to the FSAR when, in fact, changes to the FSAR
were required.
4.2.2
III.A.3.b.(2):
This paragraph documented that none of
the four mini-mods reviewed in the PAT report addressed
all the design information which was required to be
addressed by Technical Functions Procedure 5000-ADM-7350.05
(EMP-002), Revision 0-00, dated September 3, 1985,
"Mi n i-Mod s. " The team considered that all the attributes
required to be addressed by the procedure were relevant and
should be part of the modification documentation.
4.3 Conclusion
The Code of Federal Regulations,10 CFR 50, Appendix B Criterion V
requires that activities affecting quality shall be prescribed by
instructions, procedures or drawings and shall be accomplished in
accordance with those procedures, instructions or drawings.
The failure to adhere to the requirements of Procedure 5000-ADM-
7350.05 is an example of violation of 10 CFR 50 Appendix B
Criterion V.
(289/86-12-04) (see also below)
5.
Modification Installation Procedure Implementation
,
5.1 Introduction
The PAT team inspected design aspects of certain restart modifica-
tions. As a result of this review, two instances were identified in
which the actual installation of the modifications differed from the
intended design.
These team findings show a need for establishing
or implementing procedures which will assure that modifications are
installed as intended, because an otherwise adequate design can be
voided by improper installation.
The specifics associated with the team findings are described below.
- -
.
- -
-
i
.
-
..
11
.
.
5.2 (Closed) Unresolved Items 289/86-03-03 and 289/86-03-09:
Improper Installation of Modifications.
The PAT Inspection Report
50-289/86-03, paragraph III.A.1.d and III.A 3.a.(5), identified
certain problems with the installation of modifications. The
problems were noted with the installation of the air cylinders for
the two-hour backup supply air system and the installation of
permanent shielding to shield drain lines for the letdown
prefilters. Two specific problems were noted as follows,
5.I.]
III.A.I.d: Calculation 609-0293, Revision 0, " Bottle Rack
.
for RM-13h," (EFW Two-Hour Backup Instrument Air (TBIA)
'
,
Subsystem) provided the rack design for restraint of air
cylinders for the two-hour backup supply air system during
a seismic event.
Inspection of the installation by the
team revealed that no turnbuckles were installed,'the chain
restraints were loose,
"S" links were not closed, and eye
bolts were not securely fastened to the frame; which was
contrary to instructions contained in the design calcula-
tion 609-0293.
5.2.3
III.A.3.a.(5): The installation criteria established by
the licensee for the installation of shield blocks to
shield letdown prefilters (MU-F-2A and 28) was that the
center of gravity of the top blocks be no more than 12
inches off the floor, the blocks be no closer than 2 feet
to important-to-safety (ITS) equipment due to seismic
,
considerations, and that a warning sign be installed
identifying the 2-foot requirement. Site inspection of
the as-installed blocks by the team revealed that (1) the
top block center of gravity was 15 inches off the floor in
some locations, (2) ITS valves SF-V-77 and SF-V-71 were
located within 6 inches and 19 inches of the blocks,
respectively, and (3) no warning sign was installed.
This was contrary to the installation procedure for this
modification.
5.3 Conclusion
The failures to make installation of modifications in accordance with
prescribed instructions or procedures is another example of violation
of 10 CFR 50 Appendix B Criterion V.
(289/86-12-04)
6.
Corrective Action Implementation
6.1 Introduction
A number of items raised in the PAT report were repetitive of issues
previously brought to the licensee's attention based on past inspec-
tions.
Specifically, outstanding issues at TMI-1 have been:
improper implementation of administrative control for correcting
out-of-specification log readings and lack of proper control of
- -
.
.
-
. . .
12
.
design documents, such as drawings. The 10 CFR 50 Appendix B
Criterion XVI and the NRC-approved QA plan, sections 8.1.1 and 8.2.1
require, in part, that the licensee assure conditions adverse to
quality; such as, deficiencies, deviations and nonconformances, are
promptly corrected.
Specific examples of delayed and/or ineffective
corrective actions are noted below.
6.2 (0 pen) Inspector Follow Item 289/86-03-04:
Component Level
Quality Control List. Paragraphs III.A.1.f(1) and (2) identified
the various sub-systems of EFW system had different quality classi-
fication. The licensee Quality Control List (QCL) (ES-011) provides
for three basic classifications (nuclear safety related, important
to safety, and not important to safety). The QCL did not break down
the classification into component levels. The 10 CFR 50 Appendix B
Criterion II requires, in part, that the licensee identify struc-
tures, systems, and components to be covered by the quality assur-
ance program. Based on the licensee's response letter, dated
June 27, 1986, to the PAT report, the component level QCL is to be
issued by the end of 1986.
In view of the licensee's updated commitment to correct this item by
the end of 1986, the issuance of an adequate component level QCL is
,
unresolved pending completion of this licensee action and Region I
review-(289/86-12-06).
'
The PAT report also noted that the lack of identification on the QCL
of the safety grade Two-Hour Backup Instrument Air (TBIA) system.
4
The inspector confirmed on July 9, 1986, that ES-11, Revision 9,
dated July 9, 1986, classified the sub-system as important to safety
(System Number 852.6). However, the inspector also noted that the
licensee response letter, dated June 27, 1986, to the PAT report
states that the TBIA ..."has been specifically identified on the
.
QCL".. . as an important-to-safety system. As of July 8,1986, this
licensee action was in progress, but was not yet complete.
This was
1
discussed with licensee management at the time of inspection and
also at the TMI-1 SALP Management meeting, July 30, 1986.
I
6.3 (Closed) Unresolved Item 289/86-03-21: Corrective Action Related
to Out-of-Specification Operator Log Data Entries.
Paragraph
l
III.C.2 of the PAT report noted that out-of-specification log
i
entries on important-to-safety system were not effectively corrected
within a timely manner. A specific example is related to the refill
tank truck (for the EFW TBIA) air pressure being out of specifica-
tion (low) for a number of shifts.
The NRC Inspection 50-289/85-30
for the period December 13, 1985, to January 10,1986,(paragraph
3.2.8) noted similar examples with out-of-specification readings
existing for many shifts or days. Contributing to the corrective
action problem, personnel were not following related administrative
controls as follows:
out-of-specification log data entries were not circled as
--
required by the instructions on the affected log sheets;
_ _ . _ __
_,
_ . . - _ _ _ _
_._
__
__.
_ _ _ _
_
_ _ . _
- _ _ .
,
- - . _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _
.
-
..
13
.
.
explanatory notes were not made on the log sheets for out-of-
--
specification data entries as required by Administrative
Procedure 1016, paragraph 3.3.4 and
log sheet discrepancies, such as those noted above, went
--
uncorrected and apparently unnoticed during shift turnover
reviews of the logs by the shift foreman and the on-coming
operators.
This is an example of failure to take timely and appropriate
'
corrective action on handling out-of-specification log entries
(see paragraph 6.5).
6.4 (Closed) Unresolved Items 289/86-03-12, 13, and 14: Document
Updating as a Result of Facility Changes.
Paragraphs III.A.3.d,
III.A.3.e, III.A.3.f. and III.A.3.g of the PAT report discussed
items related to design document updating. The highlights of
these paragraphs and the disposition of the items is discussed
below. The lack of updated design documents was a previously
i
l
cited violation (reference NRC Inspection Report 50-289/81-22,
1
November 12,1981).
6.4.1
III.A.3.d: Certain design documents, particularly
drawings, were not updated when required administratively,
i.e., when six or more changes had been posted. A Quality
j
Assurance audit performed in September 1985 identified
)
similar problems with some of the licensee's specified
'
j
corrective actions. Also, the inspection noted that a
i
change to a procedure on "GPUN Drawings" was being recently
prepared and that the progress of this effort is relatively
(
slow. This is an example of ineffective corrective action.
6.4.2
III.A.3.e: There was no procedure for the use of the
Computer Assisted Records and Information Retrieval System
(CARIRS) and that the use of and interpretation of CARIRS
was not well understood by plant personnel.
In their
response to the PAT report, the licensee made commitments
for the more effective use of CARIRS as an aide in design
document updating. This is unresolved pending Region I
review of licensee corrective action implementation.
(289/86-12-07)
6.4.3
III.A.3.f: Two of twenty control room Piping and Instru-
ment Otagrams (P& ids) were found to be out of date and that
no audit of control room drawings had been performed since
July 1985. The licensee has responded to this matter and
noted that a check of the plant configuration control list
identified six of approximately 2,100 control room drawings
with changes outstanding for more than thirty days. Also,
the out-of-date drawings have been updated.
.
-
...
14
.
.
.
6.4.4
III.A.3.g: This paragraph, as well as paragraph III.B.S.b,
identified inconsistencies and errors in drawings and
System Design Descriptions. The licensee has responded to
the drawing inconsistencies noted and stated that, where
appropriate, corrective action has been initiated.
Collectively, paragraphs 6.4.1, 6.4.3, and 6.4.4 constitute another
example of failure to take timely corrective action for conditions
adverse to quality (see paragraph 6.5).
This item is similar to a
violation cited in NRC Inspection 50-289/81-22, November 12, 1981,
for which the corrective actions apparently have not been fully
effective.
6.5 Conclusion
Paragraphs 6.3 and 6.4 represent examples of an apparent violation
of 10 CFR 50 Appendix B Criterion XVI and QAP Sections 8.1.1 and
8.1.2 on failure to take prompt corrective action on known conditions
adverse to quality (289/86-12-08).
In order to fully resolve the programmatic problem discussed above,
a detailed review of the licensee's design document updating proce-
dures, resolution of audit findings, use of CARIRS and adequacy of
corrective actions taken will be performed by Region I and/or the
next PAT inspection.
7.
Other Significant Inspection Findings
'
7.1 Introduction
During the inspection of design changes and modifications, the PAT
team identified other issues that were considered to be significant.
These are described below.
7.2 (Closed) Unresolved Item 289/86-03-25:
Inservice Testing of Newly
Installed E N Instrument Air Valves.
The PAT Inspection Report
50-289/86-05, paragraphs III.A.1.b and III.D.2.a. b, and c, noted the
EN Two-Hour Backup Supply Air system was tested as part of its
acceptance process but no further testing had been performed and no
future testing of this system was planned. Specific examples are
noted below.
Proper operation of the E N Two-Hour Backup Supply Air System
--
depends on ten identical isolation check valves. These valves
were not routinely tested and, under normal operating condi-
tions, experience no differential pressure.
The control of each EN flow control valve depends on the
--
repositioning of a three-way air valve. These three-way valves
were not routinely tested.
.
..
-*
..
15.
- .
.
The ability of the EFW system flow control valves to fail in a
'- -
safe manner depends on a small pressurized air flask' located at
each flow control valve. Each air flask was protected from
depressurizing by a check valve, but those check valves were
also not routinely tested.
The necessity and requirements associated with additional testing of
.these valves will be further reviewed and, if necessary, referred to
the Office of Nuclear Reactor Regulation (NRR). This is an unre-
solved item (289/86-12-09).
7.3 (Closed) Unresolved Item 289/86-03-07): Cable Used in EFW System
Not Environmentally Qualified.
In reference to PAT paragraph
III.A.2.c, the qualifications of this cable were established by the
licensee and the area was extensively reviewed as documented in NRC
Inspection Report (IR) Nos. 50-289/86-06 and 86-10. An apparent
violation of NRC requirements (10 CFR 50.49) was identified along
with several unresolved issues. These issues are being tracked
separately based on the IR 86-06 review.
8.
Update on Other Findings
8.1 Introduction
The PAT report discussed other findings that were not identified as
unresolved or inspector follow items and were not assigned outstand-
ing item numbers. The inspector reviewed these issues and determined *
that the below listed items should be followed separately as
unresolved items.
8.2 PAT Report Paragraph III. A.3.h.(1): Prospective Evaluations of a
Design Change. Job Ticket CH 269 removed instrument air lines for
an E N pump recirculation line, EF-V-8A, without evidence or refer-
ence to a' proper safety evaluation. Since the valve is now perma-
nently blocked open, the air' lines are no longer needed. The
licensee response to the PAT report identified that the disabling of
air'to the valve was previously evaluated and approved by NRC. The
'
appropriate analysis was referenced in CMR No. 0515M., This is
unresolved pending Region I review of licensee internal documents
evaluating the removal of instrument air lines for EF-V-8A
(289/86-12-10).
8.3 PAT Report Paragraph III.A.3.h.(2):
Proper Completion of Safety
Evaluation Forms Regarding Safety Analysis Report Updating.
In this paragraph and in other paragraphs of the PAT report,
licensee representatives inappropriately marked applicable safety
evaluation forms as not needing SAR updating when, in fact, the SAR
addressed those systems and SAR updating was warranted.
It appears
to the inspector that either licensee personnel are not familiar with
the SAR contents or inappropriate personnel are being assigned safety
evaluation review responsibilities.
._.
.
-
..
16
-
.
In their response to the PAT report, the licensee indirectly commit-
ted to increased training in this area. The licensee should consid-
er specifically how well reviewers are trained in SAR content. This
is unresolved pending a Region I review of the effectiveness of
ifcensee training and actions with respect to SAR update
determinations (289/86-12-11).
9.
Exit Interview
The inspectors discussed the inspection scope and findings with the
licensee management at a final exit interview conducted August 14, 1986.
Senior licensee personnel attending the final exit meeting included the
following:
J. Colitz, Plant Engineering Director, TMI-1
H. Hukill, Vice President and Director, TMI-1
R. Keaton, Director, Engineering Projects, Technical Functions
E. Kintner, Executive Vice President, Office of the President
R. McGoey, Manager, PWR Licensing, Technical Functions
R. Toole, Operations and Maintenance Director, TMI-1
A representative of the Commonwealth of Pennsylvania, Ajit Bhattacharyya,
also attended the meeting.
At the exit meeting, the licensee expressed concern regarding redundancy
of effort involved in responding to this report since he has already
provided a written response dated June 27, 1986 to report 50-289/86-03.
The NRC encouraged the licensee to (1) evaluate his June 27, 1986
responses for adequacy and completeness as corrective actions for vio-
lations described herein, and (2) where appropriate, incorporate his
June 27 response by reference, to reduce redundancy.
The inspection results, as discussed at the meeting, are summarized in-
the cover page of the inspection report.
Licensee representatives
indicated that none of the subjects discussed contained proprietary or
safeguards information.
Unresolved Items are matters about which information is required in order
to ascertain whether they are acceptable, violations, or deviations.
Unresolved item discussed during the exit meeting are addressed in all
paragraphs of this report because of the nature of this inspection as
followup to previous inspection findings.
Inspector Follow Items are significant open issues warranting followup by
the inspector at a later time to determine if it is acceptable, unre-
solved, a violation, or a deviation.
Inspector follow items discussed
during the exit meeting are addressed in a majority of paragraphs of this
report because of the nature of the inspection as followup to previous
findings.
.
y
uw.
-..
.-
~-
-
, - . -
.,----,---..--e
,n.,
-.,---,,------,--,~,--e,----
..,nn..,
~n
--e,
nne
,
,
.
.
.
.
Attachment 1 - 86-12
Page 1
,
ILSP. RPT. 86-03
INSP RPT 86-12
PARA NO. SEC. lit
ITEM DESCRIPTION
PARA NO.
DISPOSITION
OUTSTANDING ITEM NO. ASSIGNED
A.1.a
Single Failure of Two-Hour Backup
2.3
Violation
86-03-01
86-12-02
Air System
A.1.b
Two-Hour Backup Ai r System Va lve
7.2
Unresolved
NA
86-12-09
Testing
(See Ill.D.2.a,b,c)
A.1.c
Two-Hour Backup Ai r System Post-
3.4.1
Violation
86-03-02
86-12-03
Modification Functional Testing
A.1.d
installation of Two-Hour Backup
5.2.1
Violation
86-03-03
86-12-04
instrument Ai r System Ai r
Cylinders
A.1.e(1)
Design input to Two-Hour Backup
3.2.1
Acceptable
NA
NA
Air System Related to Minimum
Air Pressure
A.1.e(2)
Design input to Two-Hour Backup
3.3
Violation
NA
86-12-03
Air System Related to Sizing of
Regulating Valves - Vendor
Interface
A.1.f.(1)&(2)
Safety Classification of EFW
6.2
Unresolved
86-03-04
86-12-06
System Components
A.2.a.(1)
Design input Associated with
NA
Unresolved
86-03-05
86-12-12
EFW Pump Motor Overcurrent
Assigned
Protection
A.2.a.(2)
Control of Design inputs
3.2.2
Violation
86-03-05
86-12-03
Associated with Battery Sizing
A.2.a.(3)
Design Analysis Not Available
NA
Unresolved
86-03-05
86-12-13
for 118 VAC Circuits
Assigned
A.2.a.(4)
Unverified Design input for dc
3.2.3
Violation
86-03-05
86-12-03
Distribution Panet Fuses
A.2. a . ( 5 )
Design Analysis for Minimum
NA -
Un re so l ved
86-03-05
86-12-14
Motor Sta rting Voltages
Assigned
A.2.b.(1)&(2)
Electrical isolation of Safety
2.4
Un re so lved
86-03-06
86-12-17
Grade Instrumentation
A.2.c
Environmental Qualification of
7.3
Violation
86-03-07
86-06-07
EFW Cable
(IR-86-06)
l
t
_ _ - _ _ _ _ _ - - - _ _ - - - _ - . _ . _ _ - . _ - - _ - _ _ _ _
-- . _ .
- _ _ _ .
_ _
- - . _ _ _ _ . _ . _ _ _ _ _ . - _ _ _ _ _ __
_ - - _ _ _ _ _ _ _ _ _ _ _ _ - _ - - _ _ _ _ _ - - _ _ -._-- _-__ __. -.
_.
_
.
,
.
DISPOSITION OF PAT INSPECTION ITEMS.
IwSP. RPT. 86-03
INSP RPT 86-12
PARA NO. SEC. III
ITEM DESCRIPTION
PARA NO.
DISPOSITION
OUTSTANDING ITEM NO. ASSIGNED
A.2.d
Appendix R Review - Overcurrent
NA
Unresolved
86-03-08
NA
Protection Coordination
A.2.e
Grounding Practices
NA
Inspector
NA
86-12-15
Follow item
Assigned
A. 3. d. ( 1 )
10 CFR 50.59 Evaluation for Lead
2.2
Violation
86-03-09
86-12-02
c.
Shielding
A.3.a.(2)h(3)
Procedure Adequacy and implemen-
NA
Unresolved
86-03-09
86-12-16
tation for Shielding Installation
Assigned
A.3.a.(4)
Design Verification of Lead
3.4.2
Violation
86-03-09
86-12-03
Shielding
A.3.a.(5)
Improper installation of Lead
5.2.3
Violation
86-03-09
86-12-04
Shielding
A.3.b.(1)k(2)
Implementation of Mini-Mod
4
Violation
86-03-10
86-12-04
Prog ram
A.3.c.(1)h(2)t(3)
Design Verification for Various
3.4.3
Violation
86-03-11
86-12-03
Modifications
A.3.d
Updating Design Documents
6.4.1
Violation
86-03-12
86-12-08
A.3.e
use of CARIRS
6.4.2
Un re so lved
NA
86-12-07
A.3.f
Cont ro l Room Drawing Control
6.4.3
Violation
86-03-13
86-12-08
A.3.g
Document Control Errors
6.4.4
Violation
86-03-14
86-12-08
A.3.h.(1)
Modification Evaluation for
8.2
Un reso lved
NA
86-12-10
EFW Recirculation Valve
A.3.h.(2)
FSAR Updating for Tempora ry
8.3
Un reso lved
NA
86-12-11
Modifications
8.1
Preventive Maintenance on HPS
NA .
Closed
NA
NA
Valve
IR 86-05
8.2.a.(1)(2)a(3)
Limitorque Maintenance Procedure
NA
Inspector
86-03-15
NA
Adequacy
Follow Item
B. 2. b . ( 1 )( 2 )&( 3 )
Torque Switch Setting Records
NA
Inspector
86-03-16
NA
Follow Item
-O
.g
l
s
DISPOSITION OF PAT INSPECTION ITEMS
'
ILSP. RPT. 86-03
INSP RPT 86-12
PARA NO. SEC. Ill
ITEM DESCRIPTION
PARA NO.
DISPOSITION
OUTSTANDING ITEM NO. ASSIGNED
B.3
EFW Pump Packing Procedure
NA
Inspector
86-03-17
NA
Adequacy
Follow item
u.4
Vendor Tech Manuals
NA
inspector
86-03-18
NA
follow item
B.5.a
Pipe Support Installation
NA
Un re so lved
86-03-19
NA
Drawing Deficiencies
6.4.4
Unresolved
NA
86-12-08
B.5.c
EFW Pump Coo l ing Wa te r Va l ve
NA
No NRC Action MA
NA
Position
Action Required
B.5.d
Physical Location of Block Valve
NA
Inspector
86-03-20
NA
Follow Item
C.)
Control Room Observations
NA
No NRC Action NA
NA
Requ i red
"
C.2
Operator Log Entries
6.3
Violation
86-03-21
86-12-08
C.3
Procurement of Instrument Ai r
NA
Un re so lved
86-03-22
NA
C.4
Cont ro l of Lif ted Loads and Jumpers
NA
Unresolved
86-03-23
NA
D.1.a
Surveillance Test initial Conditions
2.5
Un reso l ved
86-03-24
86-12-01
D.1.b
Change to Procedures Described in FSAR
2.5
Violation
86-03-24
86-12-02
D.2.a,0&c
Test of Newly Installed EFW Check &
7.2
Un reso lved
86-03-25
.86-12-09
Control Valves
,
E.1.2.3&4
T ra ining
NA
No NRC Action NA
NA
Action
F.1
QA Program Technica l & Design Issues
NA
No NRC Action MA
NA
Requi red
F.2
Comments Relating to QA Audits
NA -
No NRC Action NA
NA
Required
F.3
Corrective Actions
6.4.3
Violation
NA
86-12-08
F.4
Safety Review Program
NA
No NRC Action NA
NA
Required