ML20237H409
| ML20237H409 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/29/1986 |
| From: | Goldberg J NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Bright G, Kelley J, Kline J Atomic Safety and Licensing Board Panel |
| References | |
| LRP-B-020, LRP-B-20, NUDOCS 8708170198 | |
| Download: ML20237H409 (96) | |
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UNITED STATES
.,p; y Y eq'r i',g NUCLEAR REGULATORY COMMISSION
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'87 AUG 12 P12:00 August 12, 1986 cre 00cr BHua-James L. Kelley, Chairman Jerry R. K11ae Presiding Board Presiding Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission l
l','ashington, DC 20555 Washington, DC 20555 Glenn O. Bright Presiding Board U.S. Nuclear Regulatory Commission Washington, DC 20555 In the Matter of INDUIRY INTO THREE MILE ISLAND UNIT 2 LEAK RATE DATA FALSIFICATION i
Docket No. LRP
Dear Judges:
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Enclosed is the " Testimony of Donald R. Haverhamp" with attachments.
l Although some of the attachments are already part of the record as attachments to the Stier Report '(or other reports), they are included for cotivenience and reference in connection with Mr. Haverkamp's testimony.
Sincerely, i
ek R. Goldberg Acting Deputy Assistant General Counsel j
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Enclosure:
As stated l
NUCt. EAR REGULATORY COMMISSI0li j
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in the matter of MM A4 1
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B UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE PRESIDIllO BOARD I
In the Matter of
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j INQUIRY INTO TI:REE MILE ISLAND
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Docket No. LRP l
UNIT 2 LEAR RATE DATA FALSI-
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FICATIOM
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TESTIMONY OF DONALD R. IIAVERKAMP 1
O.1 Plcase state your name, position and business address.
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1 A.1 My name is Donald R. Haverl:nmp. My position is Project Engi-l l
neer, Reactor Projects Section 3C, Division of Reactor Projects, j
1 within the Region I office of the NRC, and my business ad-dress is USHRC Region I, 031 Park Avenue, King of Prussia, PA 19406.
Q.2 Please briefly describe your educational and professional bachground.
i A.2 I graduated from the United States Naval Academy in 1965 with I
a Bachelor of Science Degree in Engineering.
I completed ex-j tensive nuclear submarine officer training programs and had a broad range of supervisory responsibilities aboard one conven-
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tional and three nuclear submarines.
During this period, I 1
qualified as nuclear submarine Chief Engineer.
Since August 1975, I have been an employee of USNRC, Region I.
My as-j eignments have included being principal inspector at various
- 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 TMI-1 from February 1980 until flay 1982.
A copy of my professional qualifications and experience ir. attached.
Q.3 In October,1978, what was your professional position?
A.3 I was then the principal or project reactor inspector assigned to inspect Three Mile Island Units 1 and 2.
O.4 In that capacity, did your work include inspections of the TMI-2 facility?
t 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. documented that inspection.
During that inspection, while either in the shift supervisor's office adjacent to the
1 I I control room or in the vicinity of the shift foreman's desk in the control room,1 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
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this conversation and I became aware that the results of a re-j l
cent RCS water inventory leakage measurement indicated that unidentified RCS lenkage was greater than the technical specifi-j l
cations limit of 1 gpm.
(I believe the calculated leakage was
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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 grector 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 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?
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! 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 for operation (LCO),
l (2) the relationship of this LCO to its corresponding surveil-j lance requirement, and (3) the actions that should be taken any time the LCO limit is exceeded.
I believe that it was also my I
impression at that time that the licensed operators on shift were 1
in the process of taking this problem to operatiens department and facility management.
Nonetheless, I was concerned about l
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some operators' apparent misunderstanding about fundamental 1
aspects of the technical specifications and the actions that were i
required to be taken when LCOs are not met, both in the cur-rent instance and under other circumstances.
Therefore, I left
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the control room to discuss these issues with Mr. Jcmes Seelinger, Superintendent--Technical Support, and Acting Su-perintendent, Unit 2, in his trailer, which was located outside the TMI-2 protected area.
l Q.7 Describe your discussion with Mr. Seelinger.
i 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 leakage test results, although he may l
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1 l 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 wittiin ac-ceptable limits (less than 1 gpm) only once every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in order to be in legal 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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> acceptable leakage results were obtained.
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('id not attempt to determine whether this was a long-standing l
view or a hastily-formed justification or excuse that Mr. Floyd i
had argued to avoid a violation of the TS.
However, I in-I formed B1r. 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 1
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 leakage was less than the calculated values.
In addition,
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Mr. Floyd or Mr. Seelinger stated that RCS leakage measurements were considered inaccurate or invalid during the changing or
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transient plant conditions that occurred as a result of the l
1 plant's power ascension test program.
I do not recall my res-ponse to or acknowledgement of this matter.
I 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 plant operators were attempting to identify 1
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 be 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 vould 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 RCS leakage?
A.8 Yes.
Later that day, probably in the early afternoon,. I was shown RCS unidentified leakage test results that were accept-l able in that they showed leakage of less than 1 gpm.
I w e.s l
informed that some amount of leakage had been " identified," so c_____
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that the unidentifle'd leakageL was reduced,.' although.I.. do not; now recall whether n leak had been ' found and stopped or rei-4 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 '
7 rected, so as to reduce the amount of unidentified leakage, but r
. I do not now recall _ 'the _speelite inature of the ' input 1 error.
I-believe it was 'during the afternoon.. of the. next day,- October 10,1978 that.I was' informed by Mr. Seelinger that the PORC had met' L to review the' operation of the facility during.
. October 16-18, 1978, with the RCS unidentified leakage in ex-I cesc. of.the TS limit and that the. PORC hadf determined'.this' matter to. be a reportable '. occurrence.
Mr. Seelinger also showed me. a draft ' copy of the report ' that.was.beirig sent to the NRC Region I office.
q C.9 Did you ' discuss the unidentified 'RCS leakage ' matter with _ other NFC officials?
A.9 Yes.
Later. on October 19, 1978,. I believe. I discussed these natters during a telephone conversation with either my supervi-sor, Mr. Richard Keimig, ' or - the1 backup. project inspector for j
.j TMI-2, Mr. William Lazarus.
. On October 20, 1978, ~ J ' believe' j
Mr. Lazarus, in. my absence, prepared an input to the -Inspec-1 tion and Enforcement (IE) daily report' regarding._the TS : viola-1
' tion of RCS' unidentified leakage. requirements... I believe that ~
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I on the same day, October 20, 1978, Mr. Lazarus also reviewed q
the Ifeensee's prompt (24-hour) re, ort 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).
i 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-1 er, this occurrence was identified by the licensee and was re-f viewed by the PORC; RCS leakage was reduced to acceptable limits within the time frame 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 Mr. Seelinger and f!r. 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 i
inquiries.
However, my questioning may have led to the prac-
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tice of "round-off" of RCS unidentified leakage test results, as
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described in an operations department memorandum dt,ted October 20, 1978.
Although I did not approve the round-off.
f practice, or intend by my inquiries to imply that roun3-off might be acceptable, I was indeed aware of the implementation.
of the round-off of. test 6ta because I reviewed.the oporations memo during the inspretion, wnica it. O,-"mente in Inspection Report 50-320/78-02 (See Exhibit A).
During the week following the inspection, I made one or more I
telephone calls to an NRC person or persons in the Office of
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i ITuclear Reactor Regulation to determine the acceptability of j
l "roun d-off. "
I was informed that round-off of test data was f
i not an allowable practice, and I conveyed this information by j
1 telephone to Mr. Seelinger, who stated that the round-off prac-I l
tice would be terminated.
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I 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
,j 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
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report review,. I conducted onsite follow-up of ~ licensee event -
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report LER. 78-62/1T dated October 19,1978 (See Exhibit F),
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which regarded cyceeding the TS limit for RCS unidentified.
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leakage without ' shutdown of the unit.
At. that time I
. believed that the correction actions proposed by the licensee, j
if adequately implemented,. would have been' sufficient to d
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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 i
PORC and facility management concerning previous excessive ECS leakage (See' Exhibit ' G ' with enclosures).-
The PORC
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review and licensee management reporting of the excessive RCS leakage was performed as-required by the TSs.
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PROFESSIONAL QUALIFICATIONS of DONALD R. IIAVERKAMP I graduated from the United States Naval Academy in 1965 with a Bachelor 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-fornia, and the six-month DIG prototype qualification program at West Milton, 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 officer training programs included a broad range of supervisory responsibil-ities aboard one conventional and. three nuclear submarines.
My. principal i
I assignments, duties, responsibilities and accomplishments during that period are summarized below.
May 1967 - October 1900:
Assistant Engineer (8 months) and Supply Offi-ccr (9 months) aboard the conventional submarine USS Pomfret (S S-391).
l As Assistant Engineer,' responsible for supervision, maintenance, and oper-ation of all diesel propulsion, electrical and supporting systems. As Supply Officer, responsible for shipboard food service and repair parts manage-i
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ment.
Supervised 1 officer and 19 enlisted personnel. ' Completed one ex-tended deployment and one regular shipyard overhaul.
Qualified in Submarines.
Februhry 1969 - October 1971:
Assistant Weapons Officer (17 months) and Weapons Officer (15 months) aboard the nuclear Polaris submarine USS Na-than -Ilale (SSDP 623 (Blue)).
Responsible for supervision, maintenance.
and operation of missile and torpedo fire control, launching and supporting
.l mechanical, electrical and electronic systems. Supervised two officer and 37 enlisted personnel.
Completed final phase of shipyard overhaul, post over-haul shakedown trials and four deterrent patrols.
Received Meritorious
_1 Unit Commendation Medal.
Completed Basic Engineering Qualification (sys-tems) portion of. Engineering Officer of the Watch (EOOW) watch station.
October 1971 - November 1973:
Main Propulsion Assistant and Acting Engi-neer Officer (3 months) aboard the nuclear attach submarine USS Flasher
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(SSN 613).
Responsible for supervision, maintenance and operation of me-chanical reactor plant and engine room systems, including reactor fluid pri-H mary systems, main engines, turbine generators and associated secondary systems.
Supervised ?1 enlisted personnel.
Completed two extended de-i ployments.
Received - Navy ' Achievement Medal. ' Qualified as ' Engineering Officer of the watch and as nuclear submarine Chief Engineer.
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rebruary 1974 - June 1975:
Navigator / Operations Officer aboard the nucle-j ar attack submarine USS Billfish (SSN 676).
Responsible for supervision, i
maintenance, and operation of inertial, celestial and radio electronic naviga-j tion systems.
Supervised 1 officer and 16 enlisted personnel.
Coordinated j
departmental and shipboard training, including nuclear operator training, while in operation and overhaul status.
Planned and conducted several ex-j tensive developments.
l 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 i
principal (project) resetor inspector assigned to inspect reactors in opera-tion, including Yankee Rowe, Maine Yankee, and R.E. Ginna (concurrent-j ly). Calvert Cliffs Units 1 and 2, and Three Mile Island Units 1 and 2.
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Following the TM1-2 Accident, I was initially involved with the Region I in-cident response activities at the regional office.
From March 29,1979 until January 31, 1980, I was assigned to perform various functions primarily at l
the Tf11 site.
_ Pty initial duties were TMI-2 shift surveillance inspection; liaison support for NRC Commissioners, Congressmen, investigating groups i
and commissions, and foreign representatives; providing testimony for in-vestigations; and, TMI-2 reactive site inspection.. From February 1,1980 i
until May 29, 1982 I was cssigned as the Senior Resident Inspector for TMI-1.
1 From f ay 30, 1982, until June 21, 1982 I was assigned as the Reactor Li-censing Engineer, Division of Reactor Projects, Region I.
Since that time, I have been assigned as Project Engineer, Heactor Projects Section 3C, Di-I vision of Reactor Projects, Region I.
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I Exhibit A I
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8 NOV 1978 I
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Docket No. 50-320 Metropolitan Edison Company ATTN:
Mr.. J. G. Herbein Vice President - Generation P. O. Box 542 Reading, Pennsylvania 19603 Gentlemen:
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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 Nuc] ear Station.
Unit 2. Middletown, Pennsylvania, of activities authorized by NRC License 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 Inspection and Enforcement Inspection Report which is enclosed with this letter. nfithin these areas, the inspection consisted of selective examinations of procedures 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 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 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 Doctanent Room.
If this report contains any infonnation that you (or your contractor) believe to omcc >
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NRC Form 318 (RI) (5_76) NRCM 02040
- uly oovismens=1 nigino opeeci: e,77 244.s47
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Metropolitan Edison Company 2
8 NOV 1978 l'
i be proprietary, it is necessary that you make a written application l
i within 20 days to this office to withhold such information from public
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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 reasor s v.
j which addresses with specificity the items which will be considered by the Comission as listed in subparagraph (b)(4) of Section 2.790. The.
i 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 i
the Public Document Room.
fs No reply to this letter is required; however, if you should have any f
questions concerning this inspection, we will be pleased to discuss them
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with you.
Sincerely, 1
1 i
Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch w
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Enclosures:
1.
Appendix A. Notice of Violation 2.
Office of Inspection and Enforcement Inspection Report Number 50-320/78-32 J
I cc w/ enc 1s:
j T. Broughton, Safety & Licensing Manager j
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 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 (WithoutReport)
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& _U, S. GOVE ANMENT PRINTtNG OF FICE 1977.4237-026 NRC F ORM 318 (6 77)
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Metropolitan Edison Company.
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IE. Mail & Files (For Appropriate Distribution)-
' lL Central Files-
.i Public Document Room (PDR)
, Local Public Document Room (LPDR) (NSIC)
Nucleer Safety.Infonnation Cer.ter Technict.1 Information Center (TIC)
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. REG:X Reading Room
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Commonwealth of Pennsylvania Miss Mary V. Southard. Chairman.' Citizens for a Safe Environment t
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NRC ROAM 318 (6 77) t U. S. GOVF RNMENT PRINTING OH.lCE 1977-737-025-
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APPENDIX A 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 reconsnended in Appendix "A" of Regulatory Guide 1.33, November,1972."
Regulatory Guide 1.33, November,1972 states, in part:
"The following are typical safety-related activities which should be covered by written procedures...
A.
Administrative Procedures un
- 10. Bypass of Safety Functions and Jumper Control."
1 TMI Station Administrative Procedure 1013. " Bypass of Safety Functions and Jumper Control," Revision 7 states, in part:
(1)
. no jumper shall be installed until it has 'be$n identi-fied 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 l
information shall'be filled in the log: Date, Time, Replaced By...."
l (iii)
. When a... jumper'... is in effect greater than~12 months, it should be evaluated by the cognizant engineer for-the affected system.
1.
/The evaluation should document the reasons why tha wiring change has er,t been raade permanent (or recoved) anct wbs': final disposition (of the situation is 1ntended.... " -
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FopeFORM 318 16-77)
U. S. GO'lE RNMENT PRINTING OF FICE 19,77-Y3 7.025,
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APPENDIX A 2
i 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, li3 and #20 were replaced and the respective log sheets were not filled in with applicable information.
(iii) Jumper #3 has been in effect since July 22, 1977, a period i
of 15 months, and no evaluation has been performed.
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WRC FORM 318 (5-77)
W U. S. GOVE RNMEld. PRINTING OF FICE 1977-237-025
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1 u.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT-Region I Report No.
50-320/78-32 Docket No.
50-320 Category.
82 License No.
DPR-73 Priority Licensee:
Metropolitan Edison Comoany
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P. O. Box 542 Readino, Pennsylvania 19603
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Facility Name:
Three Mile Island Nuclear Station, Unit 2 l
Inspection at:
Middletown, Pennsylvania i
Inspection conduct October 16-20, 1978 Inspectors:
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date signed D. h erk@,Reactoreinspector date signed date signed AL"
//* ?~f8 Approved by
. R. Ke
, Chief ctor Projects date signed
/ Sectio
. 1, R0 Branch Inspection Summary:
Inspection on October 16-20,1978 (Report No. 50-320/78-325 Areas Inspected:
Routine, unannounced inspection by a reg onal based inspector of startup test results; power level plateau data; plant operations including i
shift logs and records and facility tour; licensee followup actions concerning selected previous inspection findings; licensee events; IE Circulars; and, l
selected licensee periodic reports. The inspection involved 32 inspector-hours onsite by one NRC regional based inspector.
I 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 lifted leads, Paragraph 5.a).
Region I Form 12 (Rev. April 77)
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L DETAILS 1.
Persons Contacted Metropo11 tan 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, Shift 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 l
personnel.
denotes those present at the exit interview on October 20, 1978 l-I 2.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item.(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 responsible organiza-tion. The. inspector had no further questions concerning this item.
l L
3 (Closed) Unresolved Item (320/78-18-01): Turnover of test program records. TMI Station Superintendent letter to GPU$C, 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) Noncompliance (320/78-26-01):
Failure to update emergency procedures. The licensee's corrective measures have been completed.
l as described in MEC letter to NRC: Region I, Serial GQL 1481, dated September 6, 1978. The Controlled Procedures Distribution List has been revised to include appropriate distribution of changes and j
revisions to HPP 1670.6 and HPP 1670.12 for the emergency monitoring 1
kits. Recently completed quarterly surveillance of these kits, per i
HPP 1778, included verification that the information book in each I
kit had up-to-date procedures. The inspector had no further questions i
concerning this item.
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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%
3 l
power level plateau testing completed on September 19 and l
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 l
plateau testing completed on October 4,1978)
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 management, retest conducted if required, and any system or process changes necessitated have been properly documented and reviewed.
+
5 1
4 4
3 i
Test summaries and evaluations had been performed by the cogninnt engineers, and test results had been compared with established acceptance criteria.
l I
"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 -
J document the adequacy of the test package contents, to indi-cate independent review of test records and data package j
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 committee has audited the test package, that their coninents are included and corrective action has been taken if required.
The inspector used one or more (,f the following acceptance criteria for the above items.
4 Final Safety Analysis Report i
Technical Specifications Test Instruction 7, GPU Startup Problem Report Test Instruction 9, Conduct of Test l
l Test Instruction 13, Test Interface Instructions Test Instruction-18. Test Procedure Documents Regulatory Guides l
Inspector Judgment l
Quality Assurance Program l
l l
L___-_-___-______________-_____
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 pending an acceptable retest at the 75% power level plateau (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 item is unresolved pending final T'JG approval of these TPs (320/78-32-02).
4.
Power Level Plateau Data Review a.
Verification of Licensee Evaluation 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 Monitoring 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-relation Test (40%
on October 7,1978) power level plateau testing completed TP 800/36 (MTX 147.37), Shutdown from Outside the Control Room (15% power level plateau testing completed on September 19, 1978)
SP 800/8 (MTX 91.4), ICS Tuning at Power (15% and 40%
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)
TP 800/2 (MTX 108.7), Nuclear Instrument Calibration at Power (15% and 40% power level plateau testing completed on September 18 and October 1,1978)
2 l
6.
TP 800/12 (MTX 147.22), Unit Load Steady State Test (15%
and 40% power level plateau testing completed on. September
_j 19 and September 30.1978).
1
'I TP_800/22(MTX147.30),LNSSHeat'BalanceL(15%and40%
l power level plateau testing completed on September 18 and l
September 29,1978) 1 The test records were reviewed to verify the'followf ag ' items.:
]
Test summaries and. evaluations had been performed-by the cognizant engineers, and test'results had been compared.
.j with established acceptance criteria, i
Approval of the test ~ results by thos'e personnel charged 1
with responsibility for review and acceptance has'been.
documented, and if the' off site comittee has: audited the test package, that their comments are' included and corrective
~
action has been.taken if required..
y 1
- The inspector.used one or more of the following acceptance criteria for. the above items..
'I Final Safety Analysis Report.
Technical Specifications u
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 performed.
Deletion of this test from.the power escalation testing 4
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-.approva.1.,
This item is unresolved pending final TWG approval; of the-test results (320/78-32-03).
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b.
Authorization to Raise Power
.j The inspector reviewed the licensee's evaluation of the 15%
and 40% plateau test results and the authorization for pro-
.t ceeding to the next test plateau. This review included dis-l 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.
'l Test (TWG approval received to escalate power to 40% and 1
75% on September 20, 1978 and October 17, 1978)
{
Minutes of PORC Meetings Nos. 268, 286 and 290 The review was conducted to assure or confirm the following f
items.
All applicable testing has been completed.
1 All testing anomalies have been evaluated and resolved by I
the licensee.
l The licensee has reviewed Technical ~ Specification require-ments applicable to the next higher power level and has fully implemented them, j
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.
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)
'i 1.
The-inspector used one.or more of the.following acceptance criteria for the above items.
y Final Safety Analysis' Report
. Technical Specifications
{
. Test Instruction 9, Conduct of Test; Regulatory Guides:
s.
Inspector Judgment Findings were acceptable...
I 5.
Review of Plant Operations k
~a.
Shift-Logs and Operating Records
.f The inspector reviewed the following logs and records.
Shift Foreman Log, Control Room Log' Book, Control Room i
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 ~
Shif t ~ 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 j
Fire System Removal from Service Notification Log; entries.
made during August 1 - 0ctober 15, 1978 Applications for Apparatus.to be Taken 0ut of. Service;-
a those active on October 20,'1978, and those cleared,.
j dated October 1-19,1978 Do Not Operate and Caution Tag Log; entries made.during a
August 1 - October 15, 1978 ~
j
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l Transient Cycle Log Book; entries made during August 1 i
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October 15, 1978 i
Unit 2 Operations Department' Memos.2-78-16 through 2-78-20
.l 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 imdification and. tagging opera-tions are conducted in conformance with established admini-strative controls.
l Problem identification reports confiT1n compliance with TS i
reporting and LC0 requirements.
Acceptance criteria for the above review included inspector judgment and requirements of applicable Technical Specifications and the following procedures.
S Scion 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 L. '.
-___.._.._______________._________j
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- H SAP 1016, " Operations Surveillance Program,";P,evision.12 7 SAP 1033,' " Operating Memos and Standing Orders," Original.
SAP 1037,1" Control of Caution'and DNO Tags," Revision 1
)
~
4-Findings were acceptable, except as noted below.
SAP 1013 includes the following ; requirements for administra-x tive control of jumpers and lifted-leads.
c i
(1) No jumper shall be installed.untillit 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-
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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 followingl discrepancies'on October 18, 1978.
(1) Jumper #27, at'ICS Terminal: Boar'd 10-5; was identified:
by one BLUE (lifted lead) tag vice two RE6 jumper tags.,
(2) Lifted leads #2 and #3, at Terminal Board 1T5, and lifted lead =#20, at ICS Cabinet Terminal. Board 8-1,'were re.
placed _ and the. respective-log sheets were not. filled in with applicable information.:
l (3) Jumper #3,'at the Hydrogen Seal Oil Cabinet 307, has; l
I been in:effect since; July 22, 1977, a period of.15; months ;and no. evaluation of the jumper has been made 1
by the cognizant engineer-q
11 The inspector stated that failure to conform 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 evaluat'ons were in-progress. 'In addition,. a licensee audit of a~il jumpers and lifted leads was performed to as-sure that SAP 1013 implementation and log sheet status was cor-ect.
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 inspection (320/78-32-04).
SAP 1013 contains administrative controls for temporary mechanical modifications, including installatici or re-i 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 systens.
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 Turbine Building Fuel Handling Building Control and Service Building Control Room f
Circulating Water Pump House i
1 Switchgear Rooms Inverter and Battery Rooms Makeup Pump Rooms West Cooling Tower
.)
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The following observations / discussions / determinations were made.
1 Control' Room and local monitoring instrumentation for various components and parameters was observed.
l 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.
1 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-i and fire hazards, was observed.
4 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.
I The indicated positions of electrical power supply breakers i
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.
1 Selected jumper and lifted lead markers were observed'for 1
l proper identification and the effected wiring changes were observed for proper completion.
i The Control Board was observed. for annunciators that nor---
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mally should not be lighted during the existing plant'-
l 1
conditions. The reasons for the annunciators were discussed I
with control room operators.
1 The licensee's policy and practice regarding plant tours was reviewed.
L Control Room manning was observed on several occasions during the inspection.
t i
C_---__.-________..__
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13
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Acceptance criteria for the above items included inspector judgment and requirements of 10 CFR 50.54(k), Regulatory i
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 1
SAP 1003, " Radiation Protection Manual," Revision 12 SAP 1008, " Good Housekeeping," Revision 4 SAP 1009, " Station Organization and Chain of Command,"
Revision 3 l
SAP 1028. " Operator at the Controls," Original 1
SAP 1037, " Control of Caution and DN0 Tags," Revision 1 SAP 1034 " Control of Combustible Materials," Original l
The inspector findings were acceptable, except as noted below.
Several discrepancies concerning the identification and control of jumpers and lif ted leads were observed, as described m Paragraph'5.a.
I Plant housekeeping conditions have improved since previous i
inspections.
6.
In-Office Review of Licensee Event Reports (LERs)
I 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 Abnormal Occurrence, and whether the event war-ranted onsite followup.
The following LERs were reviewed.
LER 78-50/1T, 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 cabling) denotes those LERs for onsite followup t
14 i
LER 78-51/1T, dated September 6, 1978,.and Update LER 78-.
51/1T, dated September 19, 1978 (Certain safety-related valves
'i 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 26, 1978 (Safety injection
-channel "C" did not trip during cooldown at the required RCS -
- j pressure setpoint, due to instrument bi-stable failure)
J LER 78-54/3L, dated September 27, 1978 (R. B. sump pump discharge valve to miscellaneous waste holdup tank (WDL-V271) was.not supplied with containment grade limit. switches, torque switch andmotor,duetoapurchasingerrorbytheA/E) 1 1
LER 78-55/3L, dated October 5,1978 (Control room emergency air handling system damper 4092C failed to close during sur-veillance testing, due to improper orientation of certain instrumentairtubingcomponents)
LER 78-56/3L, dated October 16,1978 (Inoperable absolute i
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)
.LER 78-58/3L', dated October 4,1978 (Containment isolation j
valve WDL-V1125 failed to close on manual initiation test signal, believed to be due to a dirty control relay contact) 4 LER 78-59/3L, dated October 2,1978 (Bolted motor lead connections 1
on containment isolation valves MU-V2A/B were not taped per i
environmentally qualified methods, due to a personne1' error during construction)
)
denotes those LERs selected for onsite followup i
i
)
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6 15 NPDES Permit 0009920 Update Noncompliance Notifications 78-05 through-78-07 NPDES Permit 0009920 Noncompliance Notifications 78-08 through j
78-15 l
NPDES Permit 00099201 Noncompliance Notifications 78 '
through 78-21 i
The above LERs were closed based on satisfactory review in the 1
Region I office, except 'those LERs selected for onsite followup.
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7.
Onsite Licensee Event Followup For those LERs selected for onsite' followup (denoted in Paragraph 6), the inspector verified that the reporting requirements of-Technicel Specifications and GP 4703 (Original) had been met, that appropra te corrective action had been taken, that the. event was reviewed 5y the licensee as required by' Technical. Specifications,
{
and that cantinued operation of thetfacility was conducted in conformance with Technical Specification limits.
The inspector's findings regarding.these licensee events were 1
acceptable, un.?ss otherwise noted below.
LER 78-54/3L described a purchasing error by the unit n/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.
l inspected.for similar errors. This corrective action is being tracked by PORC Action Item #2-78-051, which is scheduled for 1
completion by October 31, 1978.
Licensee closecut of PAI #2-l 78-051 will be reviewed during a subsequent inspection.
l 8.
IE Circular Followup The inspector reviewed the licensee's' followup. actions regarding the IE Circulars listed below.
IEC 78-06, " Potential Comon 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 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
- denotes those environmental reports subject to generic and selective onsite followup during a subsequent environmental inspection i
4
16 I
This review included discussions with licensee personnel, review 1
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 performed, and that action taken or planned is appropriate.
Acceptance criteria for the above review included inspector judgment l
and requirements of applicable Technical Specifications and facility
'i procedures.
Licensee 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 Poe to obtain information on the design of the decay heat and building spray vaults, for which no water-l 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 (320/78-32-00).
PORC review of IE Circular 78-13 was documented and closed by PAI #2-78-047.
PORC determined that TMI Unit 2 has adequate i
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-VilA-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
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 Ur.it 2.
The valves are only opera-ted manually during a loss of power, when placing the valve on its backseet for a packing adjustment, or for a limit switch adjusinent.
Thus, the potential for failure of the actuatort, 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 coong.
No additional actions for minimizing manual valve operati or procedures for verifying actuator operability were cor :dered 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 i
and that test results and/or supporting information discussed in the report were consistent with design predictions and performance speci-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 TMI 2 periodic reports were reviewed.
July Operating Report, dated August 11, 1978 August Operating Report, dated September 11, 1978 September Operating Report, dated October 10, 1978 The above reports were closed based on satisfactory review at the Region I office.
10.
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 during this inspection are discussed in Paragraphs 3, 4.a. 5.a and 8.
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1 I
i 18 1
i 11.
Exit Interview
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The inspector met with the licensee representatives (denoted in Para-l graph 1) at the conclusion of the inspection on October 20, 1978.
The inspector summarized the purpose and scope of the inspection and the findings.
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Exhibitf.B ACTION CONTROL FORM REPORT OF NONROUTINE EVENTS
~N FACILITY:
DOCKET NUMBER INITIAL REPORT NUMBER FOLLOWP REPORT NUMBER
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EVENT DATE INITIAL REPORT DATE FOf10WP REPORT DATE -
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M D D Y-Y IN OFFICE TIME EXPENDED INSERT REPORT TIPE NUMBER 1.
Reportable Occurrence Y Information f) g d MINUTES 2.
Environmental Deviation 5.
Overexposure 3.
Construction Deficiency 6.
Other Report EVENT TITLE:
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Check here if exempt from PDR Check here if No Additional Report is Expected Check here when Data is entered into computer ///7
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This report ves screened in accordance with Procedure Etaber 907123 and Regional Office Instruction 1900.
All required actions have been initiated.
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Pdject IaHTpector REMARES:
II:I Form 39 (Revised,)
D2 camber 1976
- -.. - - _ _ _ - _ _ _.. _ _ _ _ _ _ _ _ _ _ = _ _. - - _
-e Exhibit C j
A Metropolitan Edison Company Pmt Ofika Bom 40 Ptiddletwn. Pe*my vann 17057
/1/ 911 4U11 October 19, 1970 Mr. Boyce H. Grier Director of Regulatory Operations Region I 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
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 1 NRC at 1530 hours0.0177 days <br />0.425 hours <br />0.00253 weeks <br />5.82165e-4 months <br /> on October 19, 1978.
A situation considered reportable under technical specification 6.9.1.8.b was discovered at 1000 haurs on October IS.1978, when it was detemined that the liniting 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).
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.
5
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_ g gJ.L'..Seelinger Unit 2 Superintendent /
Technical Support JLS:bil Y[f'dh".Y M'l hi!?pQ* BOT 7d','i s af I/,$ TM' {' M'{; ff' * '/d @j[*' ; [j' ~1p " $,3*p m
Exhibit D
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UNITED STATES -
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f,d 4
t WUCLEAR ' REGULATORY COMMISSION -
f MEGION I -
831 PAAK AVENUS KING OF PRUS$1A. PENNSYLVAP41 A 19408 Docket Nos. 50-289 g
ISI9 50-320 /
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 j
l 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 j
Station, Units 1 and 2. Middletown, Pennsylvania, of activities auth-1 orized by NRC License Nos. DPR-50 and.DPR-73 and to the discussions of 1
l 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 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, measurements made by the inspector, and observations by the inspector.
1 Based on the results of this-inspection, it appears that one of your
-l activities was not conducted in' full compliance with NRC requirements, i
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 l
~t 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)correctivesteps.whichhavebeen'taken'byyou i
and the results achieved; (2). corrective steps which will be-taken to avoid further items of noncompliance; and (3) the date when full com-pliance will be achieved.
i o
Metropolitan-Edis' Company 9
JAN 1979 :
2 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-
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report contains'any information that you (or your. contractor) believe to be proprietary,11t is necessary that you make a written application.
within 20 days.to.this office:to withhold.such information from public L 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 4 which addresses with specificity the-items which willibe considered by
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.the Consnission as listed in ' subparagraph (b)(4)..of; Section 2.790.. ' The' information sought to be ' withheld.shallL 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 Should you have any questions.concerning this' inspection, we will'be pleased to discuss them with you..
Sincerely,.
j [ j f G,,;
, di.@'ik W Eldon J. Brunner, Chief Reac' tor Operations ~and Nuclear Support Branch
Enclosures:
1.
Appendix A Notice of Violation 2.
Office of Inspection and Enforcement Combined Inspection Report Numbers 50-289/78-23 and 50-320/78-36 cc w/encis:
.l 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 1
J._B. Logan, Unit 2 Superintendent G.-A. Kunder, Unit 2' Superintendent - Technical'. Support j
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I.^R. Finfrock, Jr.'
'i Mr. R. Conrad.
G. F. Trowbridge,. Esquire j
Miss Mary V.,Southard, Chairman, Citizens for a Safe Environment (WithoutReport) l 1
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i Metropolitan Edison Company 9
JAN 1979 3
1 bec w/encls:
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IE Mail & Files (For Appropriate Distribution)
Central Files 1
f Public Document Room (PDR)
Local Public Document Room (LPDR) (NSIC) 1 Nuclear Safety Information Centar Technical Infonaation Center (TIC)
I REG:I Reading Room.
Region Directors (III. IV)(Report Only)
Connonwealth of Pennsylvania Miss Mary V. Southard, Chairman, Citizens for a Safe Environment 1
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APPENDIX A NOTICE OF VIOLATION 1
Metropolitan Edison Company Docket No. 50-320
-1 Based on the results of an NRC inspection conducted ca December 4-8 and j
12-14, 1978, it appears that one of your activitics was not conducted in i
full compliance with conditions of your NRC F:cility License No. DPR-73 as indicated below.
This item is a Deficiency.
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Technical Specification 4.6.1.1 states, in part:
" primary CONTAIN-NENT INTEGRITY shall-be demonstrated:
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At least once per 31 days by. verifying that:
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All penetrations *... are closed by valves...".
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- 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-1 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.
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NUCLEAR REGULATORY COMMISSIL.,
OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-289/78-23 Report No.
gn 1?n/7A 16 50-20.
Docket No.
Sn R?n C
DPR-50 License No. npp 73 Priority Category B2 Licensee:
Motronnlitan Fdison Comnanv P.O. Box 542 Readino. Pennsv1vanda 19640 Facility Name:
Three Mile Island Nuclear Station, Units 1 and 2 Inspection at:
Middletcwn, Pennsylvania l
Inspection conducted:
Dec mber 4-8 and 12-14,1978 7
I Aw
//4 /~7 T Inspectors:
'date signed j
D. R. Haverkamp, ReactM Inspector h P. M~
//v h 9 date signed l
d) R. JoSVson, Reactor Inspector Trainee h$
r /v /v ?
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'dat'e signed P. D. G cto,r Inspector Trainee
/ - a'"- 7 8 2
Approved by:
/
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- 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 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br /> 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 locatedinsidecontainment, Paragraph 4).
Region I Form 12 (Rev. April 77) lu--__---_-_-_
k DETAILS l '.
Persons Contacted Metropolitan Edison Company Mr. R. Barley, Unit l' Lead Mechanical ~ Engineer--
Mr. R. Bensel,' Unit 2 Lead. Electrical. Engineer -
- Mr.'M. Bezilla, Unit 2 PORC Secretary
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i Mr. J. Chwastyk', Shift. Supervisor Mr. J. Floyd, Unit 2 Supervisor, af 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
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Mr. V. Orlandi,-Unit-1 Lead ~ Instrumentation:and Controls Engineer l
Mr. I. Porter, Unit 2 Lead-Instrumentation!and Controls Engineer l
- Mr. M..Ross, Unit 1 Supervisor of Operations a
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Mr. F. Scheimann,:Jr., Unit 2 Shift Foreman
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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
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Mr. C. Gatto, Lead Mechanical Test Engineer Mr. R. Toole, Test Superintendent i
The inspector also interviewed several other ~1icensee employees during the inspection. They included control room operators,-
l technical and engineering staff personnel, and general office l
personnel.
- denotes those present at the exit interviews on December 14, 1978.
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- T Licensee / ction on Previous Inspe,ctinn Findings A
2.
1 289/78 02-01:
LER 77-25/3L Cor -
(C1csed)
Inspector Foflowup Item L
rective' Action.. Installation of. permaer.t piping for seal water makeup to tha4C evaporator ~was completed per C/M No. 455 and Work B.
Requesth 10829 and,10830. The-inspector'had no further questions concerning this item.
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(Closed)' Inspector Followup Item'289/78-13-02:
LER 78-17/lT.Cor-rective Action.
Reduced RCS High Pressure Trip setpoints were '
spproved 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 Chances Common to Units 1;an6 2.
Effective temporary changes applicable to both Unit 1 anG 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-
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cedures.
The 1,nspector he,d'no further questions.cancerning.this item.
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(Closed) Noncompliance 320/78-24-01: Electrope~ Storage Oven Temperature Less Than Required. The licensee's corrective measures were completed as described in MEC Letter to NRC Region I, Serial.
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.GQL 1532,~ dated September 18,1978.
The overall program for weld i
rod control was reviewed t,yGpuSC QA personnel 'and discussed with a
appropriate construction contracter' representatives.. During'fre-quent QC inspections of work in.progre;;s, the storage and distri-bution of weld rods and the temperatu'res of holdg and baking ovens-were found to be acceptable. ~1nfaddition, the me of, weld rod at J
out-of-specification' temperature cohditions 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.
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(Closed) Unresolved Item 320/78-24-06:
IEB 78-01 Corrective Actions.
Valoz type contact arm retainers were installed in applicable 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.
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4 (Closed)
Unresolved Item 320/78-29-02: TP 272/1, Main Feed Pump, 4
Exception E-27.
During performance of TP 800/23, Unit Load Trans-ient Test, the plant attained 74% power with one operating main f
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 concerning 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 i
based on four previous acceptable tests performed per TP 330/5.
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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-j viewed recent Unit 2 GRC Meeting Minutes and identified no inad-ecuacies concerning quorum requirements. The inspector had no i
further questions concerning this item.
(Closed)
Unresolved Item 320/78-29-05:
Preparation and Review of PORC Meeting Minutes. Written PORC minutes have been prepared 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 roview.
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 l
The appears adequate for future control of fire extinguishers.
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.
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Inspector Followup Item 320/78-29-08: Unplugged Piping Penetration.
The fuel oil storage tank cross-connect pipe pene-tration has been plugged per ECM 5-9085. The inspector had no 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 j
a retest completed on October 26, 1978. The inspector had no
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(0 pen)
Inspector Followup Item 320/78-32-07:
LER 78-54/3L Cor-rective Action.
The qualification of Siemans-type operators used l
with CA-V3, CA-V4A and CA-V4B has not yet been determined 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 i
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 operators is planned for the earliest convenient outage.
Final licensee evaluation of Siemans operators usage and replacement will be reviewed during a subsequent inspection.
3.
plant Tour (Units 1 and 2)
Upon arrival at the site at 6:15 a.m. on December 4,1978, the j
inspector proceeded directly to the Unit 1 and Unit 2 Control Con-Rooms to observe plant operations during off-normal hours.
trol Room manning and control board monitoring instrumentation and equipment controls were observed for conformance with appli-t cable Technical Specification requirements. The inspector then
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conducted a tour of the Unit 2 Auxiliary Building to check for j
I general cleanliness and housekeeping conditions, potential fire hazards and adequacy of radiation controls. The tour was com-i I
pleted at 8:30 a.m.
Findings were acceptable, except as noted below.
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6 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-
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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-10 and MU-T-1A cubicles,-
which were identified by radiation work pemits 'as radiation The radiation work pemit for the seal return cooler areas.
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-3 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 acceptable.
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, Limiting Safety System Settings and Limiting 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 logs and records were reviewed on a sampling basis.
Shift Foreman Log l
Control Room Log Book 1
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Operating Procedure (OP) 2102-1.1, " Unit Heatup," Revision 16; completed December 1, 1978 q
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OP 2102-1.2, " Approach to1 Criticality," Revision 5.(TCN 2-78-669);
j completed December 3, 1978 l
OP 2102-1.3, " Unit Startup," Revision 10 (TCNs 2-78-665, 2-78-667, I
2-78-670,2-78-700,2-78-709); in progress on December 7, 1978 i
l 0P 2102-2.1, " Power Operations," Revision 9 (TCN 2-78-701);
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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 j
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OP 2102-3.2, " Unit' Cooldown," Revision 10 (TCNs 2-78-615 2-78-671); completed September 23, 1978 I
OP 2102-4.1, " Reactor Building Purge and Purification," Re--
. vision 3; partially completed February 17, 1978 1
OP 2103-1.1, " Filling and Venting the Reactor Coolant System,"
I Revision 8 (TCN 2-78-694); partially complet:d September 24, l
1978 OP 2103-1.2, " Soluble Poison Concentration," Revision.4; con-trol room file copy OP 2103-1.3, " Pressurizer Operation," Revision 3; partially i
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 (TCN 2-78-688); 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-i l
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OP 2104-6.2, " Emergency Diesels and Auxiliaries," Revision 8;
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completed May 30 and Dircember 8,1978 j
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OP 2104-6.3, " Emergency Feedwater," Revision 4; Appendix A-
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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
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OP 2105-1.1, " Nuclear Instrumentation," Revision 2; completed October 9, 1978
.1 OP 2105-1.2, " Reactor Protection System," Revision 4; partially f
completed August 25,- 1978 l
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 2107-1.2, " 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,.0ctober 3-15, November 3-10, and December 1-6, 1978 SP 2301-3D1, "RCS Inventory," Revision 2; completed during
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October 1-December 11, 1978 SP 2301-W1, " Weekly Surveillance Checks," Revision 4 (TCNs i
2-78-657,2-78-711); completed during October 5-December 7, j
1978 SP 2301-W2, " Station Storage Batteries and Chargers Weekly Check," Revision 2; completed during October 4-December 6, 1978
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9 SP 2301-M2, " Boron Injection System Valve Lineup Verifica-tion," Revision 2; completed during July 26-December 8,1978 SP 2301-M4, " Remote Shutdown Instrumentation," Revision 3; completed during August 28-December 5,1978 SP 2301-M5, "RCP Seal Return Measurement," Revision 1; com-i l
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 l
SP 2301-M8, " Containment Integrity Verification," Revision 6 (TCN 2-78-673); completed during August 23-December 7,1978 SP 2301-Mil, "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 i
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
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SP 2303-M16A/B/C/D, " Emergency Diesel Generator and Cooling l
Water Valve Operability Test " Revision 8; completed during l
l 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 1
SP 2303-Q3, " Hydrogen Recombiner Functional Test," Revision 2; completed October 11, 1978 j
SP 2304-W1, " Borated Water Source Concentration Test," Original; completed during August 7-December 12, 1978 1
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SP 2304-M1, " Core Flood Tank Boron Concentration," Revision 1; completed during July 25-December 8,1978
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SP 2304-SA1, " Building Spray NaOH Tank Concentration and Volume," Revision 2; completed September 26, 1978 SP 2311-2, " Minimum Temperature for Criticality," Original; I
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; i
completed during August 2-December 2,1978 The observations and records review were conducted to verify that i
startup, power and/or shutdown reactor operations were in conform-i l
ance with Technical Specification safety limits, limiting safety system settings, and limiting conditions for operation.
l 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).
j Reactivity Control and Power Distribution Technical Specifica-l l
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, i
i 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
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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, i
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 1
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f 11 Plant and Electrical Power Systems Technical Specifications:
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 l
or inadequately completed operating procedures:
OP 2102-1.3 (in progress on December 7, 1978) - Step a.
. 4.1.40 and subsequent steps were performed, but were not initialed as being completed; b.
OP 2102-3.2 (completed September 23,.1978) - Steps 3.6, 3.7, 4.2.2 and 4.6.a were not initialed as being completed; 1
Op 2102-4.1 (partially completed February 17, 1978)... All-prerequisite steps were not initialed as being completed 1
c.
and Appendix A Valve Lineup was not fully completed; l
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; 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 initialed as being completed; OP 2104-1.1 (partially completed August 22,1978) - Steps g.
3.1 and 3.2 were not initialed as being completed; l
h.
OP 2104-1.2 (completed November 19, 1978) - Appendix A 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; i
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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.- (partially completed August 25,1978) - Steps 4.4, 4.5.B(1)-(14) and 4.5.B(18)-(26) were not initialed i
as being completed; OP 2105-1.3 (partially completed October 9, 1978) - Sec-n.
tion 4.2 steps were not initialed as being completed; l
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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 precedure was not annotated with the date of performance.
l 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:
l implementation and review.
Licensee representatives stated that operators would be reminded of.their responsibilities for proper i
procedure completion.
This item is unresolved pending review of j
licensee corrective actions-and selected, completed operating procedures during a subsequent inspection.
(320/78-36-01).
The inspector noted the following examples of improperly l
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; 9
b.
OP 2102-4.1
. Several working copy prerequisite and purge i
procedure steps were initialed as being completed;'and, 1
l 1
13 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 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-S1 incorporates various Technical Specification sur-veillance requirements to be performed at once per shift, 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or daily frequencies. The inspector noted the following examples of improperly implementing SP 2301-51:
Baron reductions were made on 5 occasions without com-i l
a.
pleting Appendix H, as required by SP 2301-51; b.
Performer and/or approver signatures were missing on several occasions; Various parameters were not recorded or were incorrectly
{
c.
recorded on several occasions, including containment atmosphere and gaseous monitoring system channel checks,
{
RPI/ API / group control rod positions, condensate storage l
tank level, operational mode, R.B. purge valve accumulated l
time, RPS channel check, source range flux, BWST temper-l ature, R.B. pressure deviations and pump / flux contact monitors; and, 1
l d.
Unapproved minor changes were made to required data, i.e.
l "NR" to "WR", of SP 2301-S1 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.
I l
(320/78-36-03)
14 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 25 of corresponding control room instru-ment values.
Prior to the end of the inspection, SP 2301-M4 was performed again with the results being acceptable.
The inspector noted that the prescribed acceptance criteria was not appropriate for all instrument comparisons.
Irj 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)
I SP 2301-M5, Revision 1, was issued on September 29, 1978 to l
provide an improved method of calculating RCP seal return flow.
The inspector noted that the revised procedure omitted a square j
root sign in the equation used for the flow computation.
This error resulted in higher than actual calculated seal return I
flows from each pump for the past three months.
The error was conservative with respect to Technical Specification RCS leakage limits.
Prior to the end of the inspection, a TCN was prepared to provide the correct equation. The inspector had no futther questions concerning this it;m.
The inspector noted two inadequacies with SP 2303-M13 Revis-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.
Technical Specification 3.6.1.7, which became effective on February 8, 1978, requires the accumulated time with any con-tainment purge supply and/or exhaust valve open, when in Modes 1, 2, 3 and 4, to be < 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> for the preceding 365 days.
In addition, OP 2102-T.1 Revision 3, dated April 18,1978, de-l 1eted Appendix C and required recording of the time, when these valves are open, in a log book kept at control room panel 25 where the valves are operated.
SP 2303-M13 requires revis-I 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, j
as well as Reactor Building purge and depressurization opera-f tions. This item is unresolved pending completion of the above corrective actions.
(320/78-36-05) i
-- A
l lq 15 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 penetrations shall be verified closed during each cold shut-down (Mode 5) except that verification of these penetrations i
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 containment 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 o.n August 26, 1978, while in Mode 5.
The plant entered Mode 4 on August 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 perform surveillance of valves inside containment is considered en Item of Noncompliance at the Deficiency level of severity.
(320/78-36-06) 5.
Cleanliness (Unit 2) l a.
Proaram 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 Primary System Openings,"
Revision 2 SAP 1034 (Unit 2 Only), " Control of Combustible Materials,"
Original 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 l
included requirements for the following items.
I i
i
16 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 q
i i
' 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.
l 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 Building, Auxiliary Building, Turbine Building and Control Building to verify that the program.for housekeeping and cleanliness control is. effective.
l 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.
Reactor Protection System Grounding System Testing (Units 1 and 2)-
6.
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 1etter 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.-
L 1
l L
1
~17
=
The preliminary safety concern proposed the following hypothesis:
1 a NI/RPS channel may experience a loss of ground to its instrument.
I comon without the loss of ground being evident; given this. con-
{
dition, a single postulated failure in one channel can leave the
. The concern exists for those plants j
RPS in an unanalyzed condition.
that utilize a ground as an active return path, including TMI: Units I and 2.. B&W recomended that applicable facilities -institute a-periodic test of the NI/RPS to assure that ground has not been lost.
i NRC:NRR detemined 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 recommendations
.I 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 4
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 Procedurezl303-4.1
" Reactor Protection System," Revision 29, dated October.16,1978, includes checks for'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 commons.
Licensee 1
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.
7.
Stem Mounted Limit Switches - Environmental Qualification (Units 1
1 and 2) i 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 NAMCO-type SMLSs.
4 18 i
l 1
The inspector reviewed the' applicability of this problemLat both TMI units. With' respect to Unit 1. no NAMCO-type SMLSs are used -
inside containment for containment'. isolation 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 i
NAMCO SMLSs were a different model than those identified as environ'-
mentally unqualified.
Licensee representatives statedcthat the l
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 I
unresolved pending verification that the above Unit 2 NAMCO-type 1
SMLSs are qualified.
This will be accomplished during a subsequent -
l inspection at the corporate office.
(320/78-36-08) 1 8.
Unresolved Items Unresolved items are matters about which more information is re-quired in ceder to ascertain whether they are acceptable items, l
items of noncompliance, or deviations.
Unresolved items disclosed during the inspection are discussed in Paragraphs'4 and 7.
I 9.
Exit Interview 1
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.
l l
l' i
i C_.___.______1____
______z___________.____.
l bExhibitE.
7 %,
UNITED STATES t
[
d i4UCLEAR REGULATORY COMMISSION
'd j f REGION 1 -
3
. pf
$31 P ARK AVENUE KING OF PRUS$lA, PENNSYLVANIA 19406 s
,DocketNos.50-289 2 9 JAN 1979 50-320 Metropolitan Edison Company ATTN: Mr. J. G. Herbein 3
Vice President - Generation P. O. Box 542 Reading, Pennsylvania 19640
]
1 Gentlemen:
)
Subject:
Combined Inspection 50-289/79-01; 50-320/79-01 This refers to the inspection conducted by Mr. D. 'Haverkamp of this j
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 fin. dings 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 I
Inspection and Enforcement Inspection Report which is enclosed with this j
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 6f 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 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 i
from public disclosure.
Any such application must be accompanied by an affidavit executed by the owner of the infonnation,'which identifies the document or part sought to be withheld, and which contains a staternent of reasons which addresses with specificity the items which'will be considered by the Commission 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 l.
will be placed in the Public Document Room.
)
1 i
l Metropolitan Edison Company ~-
'2 2 9 JAN 1979 q
1 No reply to this letter is required;' however 'if you should have 'any:
l questions concerning this inspection, we:will be pleased to-discuss them 1
J with you.
Sincerely,
)
E on
. Brunner, Chief s
Reactor Operations and Nuclear.
Support Branch-3
Enclosure:
Office 'of Inspection and' Enforcement Combined Inspection Report Numbers 50-289/79-01; S0-320/79-01
~
3 cc w/ enc 1:-
4" 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 1
G. A. Kunder,- Unit 2 Superintendent - Technical Support I. R. Finfrock,.LJr. -
Mr. R. Conrad G. F. Trowbridge, Esquire Miss-Mary V. Southard, Chairman, Citizens' for a Safe Environment-
.(Without Report) bec w/ enc 1:
-IE Mail & Files (For. Appropriate Distribution)
Central Files Public. Document Room (PDR)
Local Public. Document Room (LPDR) (NSIC)~
Nuclear Safety Information Center Technical Information Center-(TIC)
REG:1 Reading Room RegionDirectors(III,!Y)(ReportOnly)-
Commonwealth of. Pennsylvania '
j Miss Mary V. Southard. Chairman, Citizens for a Safe Environment t
omcc >
aver amp /cgg ge,_,___,,,_______,,,__,,______._,,___
sunnus >
j 7yc[
- I i
- 3. NUCLEAR REGULATORY COMMISSI 0FFICE OF INSPECTION AND ENFORCEMENT Region I 50-289/79-01 Report No. 50-320/79-01 i
-1 50-289 Docket No. 50-320 -
C DPR-50 Category. C License No. DPR-73 Priority Licensee:.. Metropolitan Edison Company P. O. Box 542 li Reading, Pennsylvania 19640 F6cility Name:
Three Mile' Island Nuclear Station, Units 1 and 2 Inspection at: - Middletown, Pennsylvania' and Reading, Pennsylvania j
l Inspection conducted:
. January 8-11, 1979
/-2 6 ? 9-Inspectors:
J D. R. Haverkamp, React 8 Inspector.
date signed i
1 date signed date signed
//y4 ff i
Approved b :
. R. KeimIg, Chief, Reactor Projects Section
'date 'si gn'ed No.1, R0 & 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 reoional 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 :
events and periodic. reports (Unit 2); and, licensee # followup to'IE Circular.
78-08 and previous. inspection findings (Units land 2). The inspection' involved 4 inspector-hours 'onsite for UnitI,,16 inspector-hours onsite for Unit 2, and-.
8 inspector-hours at the corporate office by one-NRC' regional. based inspector.
Results:.No items of noncompliance were identified.
Region I Form 12
.(Rev. April'77)
b 4
i i
DETAILS 1.
Persons Contacted Metropolitan Edison Company - Three Mile Island t
-i Mr. R. Earley, Unit 1 Lead Mechanical Engineer l
l Mr. K. Hoyt, Unit 2 Shift Foreman
)
- Mr. G. Kunder, Unit 2 Superintendent - Technical Support 1
Mr. J. Logan, Unit 2 Superintendent l
Mr. F. Scheimann, Jr., Unit 2 Shift Foreman l
Mr. M. Shatto, Unit 1 PORC Secretary Mr. B. Smith, Shift Supervisor Mr. W. Zewe, Shift Supervisor l
Metropolitan Edison Company - Corporate Office
- Mr. R. Harding, Unit 2 Lead Licensing Engineer
- Mr. G. Troffer, Manager - Generation Quality Assurance The inspector also interviewed several other licensee employees during the inspection. They included control room operators, l
licensing and engineering staff personnel, and general office personnel.
- denotes those present at the exit interview onsite on January 10, 1978.
' l
- denotes those present at the exit
- interview at the corporate i
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 licensee.
However, such operation will not be perfonned without NRC/NRR approval. The inspector had no further questions concerning this item.
i 1
t 3
(Closed) Unresolved Item 289/78-19-02:
LER 78-24/1T Corrective-1 i
Action.
Temporary Change Notices78-261 through 78-267 have 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-l nical Specifications. The inspector had no further questions 4
concerning this item.
(Closed) Unresolved Item 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.
Pennanent revision of sap 1002 is in progress. The inspector had no fur-ther questions concerning this item.
(Closed) Unresolved Item 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 i
for discussion in the operator requalification program. The inspector had no further questions concerning this item.
(Closed)UnresolvedItem 320/78-29-06: Licensee Review of IE 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.
q y
1 4.
(Closed)'UnresolvedItem' 320/78-36-08:
Environmental Qualification Testing of_NAMCO - Type SMLSs.
NAMCO-type stem mounted limit -
q m-switches, used for position. indication of R.B. purge supply and j
exhaust. valves, were tested for environmental. qualification, as-described in' paragraph 3 of this report.- The' inspector had no
'1 further questions concerning this item.
- 3. -
IE Circular 78-08 Followup (Units' 1 and 2) j
.q
. d 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 1
of the following selected records at the corporate office.
j Generation Division Service Requests 780260.780261,780292[
b l
and 780302 (used to assign: responsibility for review of IE-Circular 78-08 and referenced material) 1 Electrical Connector / Penetration Concern Sumary (Licensee drafted)-
Union of Concerned Scientists:Sumary (Licensee drafted)
Sumary of IE Circular 78-08 Re' view (Licensee drafted)J I
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):
./q 1
Burns and Roe, Inc. letter to MEC serial 4301-GP, datedi November 9.1978-(TMI-2 electrical equipment = environmental.
qualification) j MEC memorandum serial.GQM 5162, dated November 8,'1978 L
(verification of no failures of electrical components located
.i inside containment at.TMI-1 and TMI-2' as a result of adverse
)
environmentaliconditions) i l
MEC memorandum serial GEM 5147, dated November 7,'1978.
-(description of enginee41ng review and verification that i
' installed safety-related eiectrical equipment at'TMI 1
'is environmentally qualified)-
'i 1
- l
'j
i 5
I GPU/ Burns and Roe documentation sent to MEC (Review of TMI-2 i
safety-related electrical equipment in relation to IE Circular
]
78-08 concerns)
]
l 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 l
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 recardinkion licensee followup to IEC 78-08 were as described in 0IE Inspec Report No. 50-320/78-29, paragraph 8.
I 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 1
personnel during the 1979 refueling cutage commencing in l
mid-February. The QC surveillance report is scheduled to l
l be published by April 1, 1979.
This item is unresolved, l
pending NRC review of the TMI-1 field verification (289/
79-01-01).
4.
Review of Plant Operations (Unit 2) a.
Shift Logs and Operating Records 1
1 The inspector reviewed the following logs and records.
l Shift Foremen Log, Control Room Log Book, Control Room l
l 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 L
l 2
{
l 6
{
Shift and Daily Checks, dated October 16 - December 31,-
i 1978.-
1 Jumper, Lifted Lead, and Mechanical Modifications Logs (active and cleared); entries made during October 16 =
.I' December 31, 1978, and selected Jactive 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; j
those active on January 10, 1979 and those cleared, dated i
December 28, 1978 - January 9, 1979.
Do Not Operate and Caution Tag Logs; entries made during 1
October.16 - December 31, 1978.
i i
Transient Cycle Log Book; entries made during October l
16 - December 31, 1978.
i 1
Unit 2.0perations-Department Memos 2-78-17 through 2-78-25.
The logs and records were reviewed to' verify'the following items.
j Logkeeping practices and log book reviews are conducted l
in accordance with established administrative controls.
Log entries involving ' abnormal conditions are sufficiently detailed.
Operating 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 conformance'with established administrative controls.
Problem identification reports confirm compliance with TS reporting and LCO requirements.
- l
l 6.
7 1
,j
. Ac'ceptance criteria for the: above review included inspector-1 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 Pmgram,"
Revision 12, TCN 2-78-736.1 SAP 1011. " Controlled Key Locker. Control," Revision 16.'
SAP 1012. " Shift Relief.and Log Entries," Revision 8.
j 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.
-l No items of noncompliance.were~ identified.
1 i
b..
Plant Tour
{
1 Upon arrival at the site at 6:45. a.m. 'on Januaryl8,'1979,..the j
R inspector proceeded directly to the Unit.2 Control Room to:
observe plant operations during off-normal-hours.
Control-Room manning and control board monitoring instrumentation and' equipment were observed for; confonnance 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' d
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.
j Auxiliary Building!
Turbine Building l
s i
8 l
Control and Service Building Controi Room Switchgear Rooms Inverter and Battery Rooms Makeup Pump Rooms The following observations / discussions / determinations were
)
i made.
l i
Control Room and local monitoring instrumentation for j
l various components and parameters was observed.
Radiation controls established by the licensee, including 1
the posting of radiation and high radiation areas, the
'I condition of step-off pads, and the disposal of_ protective clothing, were observed.
Radiation Work Permits used for j
entry to radiation and controlled areas were reviewed.
Plant housekeeping, including general cleanliness conditions and storage of materials and components to prevent safety-l i
and fire hazards', were observed.
Systems and equipment in all areas toured were observed 1
for the existence of fluid: leaks and ' abnormal piping l
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 l
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.
i i-
)
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.
1 i
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
'4 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 Comand,"
Revision 3.
SAP 1028, " Operator at the Controls," Original.
SAP 1037, " Control of Caution and DNO Tags," Revision 1.
SAP 1034, " Control of Combustible Materials," Original.
No items of noncompliance were identified.
J 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 infomation was required from the licensee, whether generic implications were involved, whether the event should be classified as an Abnormal Occurrence, whether the information involved with the event should be submitted to Licensing Boards, and whether the event warranted onsite followup.
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i I
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The following LERs were reviewed.
LER 78-60/3L, dated October 13,1978 (R.B. pressure switch i
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 rod test, the nuclear overpower trip setpoint was not verified within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to using special test exception of Technical Specifications)
LER 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 z
.l requirements) 1 LER 78-63/3L, dated November 28,1978 (ratchet trip of Group _,
1 5 control rods during nonnal 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 i
l 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-l l
.I l
C.R.D. trip breakers were closed on three occasions with only one source' range detector operable)
LER 78-67/3L, dated December 11,1978-(during load service testing, fuses blew in battery chargers 2-2A and 2-2BLdue to i
defective gating and filter modules, which resulted in loss l
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 performed during heatup prior to closing C.R.D. breakers, due to procedural' inadequacy)
- denotes those LERs selected for onsite followup
i 11 LER 78-71/1T, 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, cue to an inoperable logic relay)
NPDES Permit 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 Regien I office, except those LERs selected for onsite follokup.
6.
Onsite 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 met, 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.
i 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 2-2B, due to blown fuses which occurred during load l
service testing surveillance.
Two defective gating and filter i
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 licensee 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 l
setpoint drift.
Future corrective action to prevent recurrence is still being investigated by the licensee, as tracked by PAI l
2-78-057.
This item is unresolved, pending NRC review of additional licensee corrective action (320/79-01-02).
I i
l
- denotes those LERs selected for onsite followup l
[
- denoted those environmental reports subject to generic and selective
.l l
onsite followup during a subsequent environmental inspection A
l
(
1 12 1
7.
In-Office Review of periodic Reports'
)
1 The periodic. reports listed below were reviewed in the Region I 1
i office to verify that the report included infonnation required to be reported and that test results and/or supporting information discussed in the report were consistent with design predictions l
and perfonnance specifications, as applicable. The reports were also reviewed to ascertain whether planned corrective action was adequate for resolution of. identified problems, where applicable, I
and to determine whether any information contained in the report-should be classified as.an Abnonnal Occurrence.
'i The following TMI-2 periodic reports were reviewed.
October Operating Report, dated November 15, 1978 1
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-i graph 1) at the conclusion of the inspection on January 10 and 11, 1979.
The inspector summr 'ted the purpose and scope of the inspec-I tion and the findings.
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-Exhibit F
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METROPOLfl AN EDISON COMPANY-u; w, ce cem... tveuc cr._mes ecuur.r.j a
POST OFFICE BOX 542 RE ADING, PENNSYLVANIA 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 19h06
Dear Sir:
Three Mile Island Nuclear Station, Unit 12 (TMI-2)
Operating License No. DPR-73 Docket No.'50-320 In accordance with Section 6.9.1.8.b of our Technical Specification (T.S.)
attached is Licensee Event Report (LER) 78-62/1T. This event-concerns action b of T.S. 3.h.6.2 pertaining to unidentified leakage in excess of allowable T.S. limits.
Sincerely,
/j J. G, Herbein Vice President-Generation y
JGH:RAL:ejg
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' EVENT DESCRIPTION AND PROBA8LE CONSEQUENCES h.
g IDuring performance of surveillance procedure 2301dD1 en October 10.107A: '
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. oCCURRENCf ~ REPomT REVISION stoutNTIAL REPomt No.
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CAUSE DESCRIPTION AND CORRECTIVE ACTIONS h h
f g 1 Misinterpretation of T.S. 3.h.6.2 and h.h.6.2 led to an increased frecuenev of
'l-i i i performance for the surveillance above that recuired by the T.S.
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1 g y3 1 clear to personnel involved as to which set of data taken came within the T.S.
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'I requirement and when the time requirements of the action statement vere annlicable. l -
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Unidentified leakare was subseouentiv reduced te within' the m116vak1. Tenn+'ai 1
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1 Licensee W ent Report 1
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. #27 Cause Description and Corrective Actions - Cont'd I
' limits at 0735 on 10-18-78.
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i NARRATIVE TO LER 78-62/1T' At 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> 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
]
i statement was not invoked. The largest unidentified leakage during this period was 2.6 gpm.
]
This event was caused 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 df the action statement were applicable..
j However, action was being taken to reduce: the unidentified leakage - to j
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 l
applicable action-statements when the provisions of the LCO's are not met.
Inque data for the computer program which calculates unidentified leakage 1
h11 also been clarified.
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Exhibit G C3
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4, RCS Inven_ tory PORC and Facility lianagement Actions t
The inspector reviewed the actions ta,ked by the Plant Operations Review
~
Committee (PORC) and facility management concerning previous excessive Reactor Coolant Systeu leakage.
The review included discu sions with Operation Departuent supervisors and review of the following licensee records:
Hinutes of Unit #2 Operations Review Committee Meeting #290, conducted during October 17, 18, 19 and 20, 1978.
.i Minutes of Unit #2 Operations Review Committee Meeting #292,
{
conducted during October 30 and 31, and November 1, 2, and 3,1978.
l Minutes of Unit #2 Operations Review Committee Meeting #79-10, conducted during March 5, 7, 8 and 9,1979.
l Met-Ed letter to NRC Region I dated October 19, 1978, Reportable Occurrence No. 78-62/IP.
Licensee Event Report 50-320/78-62/0lT dat2d November 1, 1978; Failure to comply with Technical Specifict tion 3.4.6.2 Action Statement b, when unidentified Reactor Coclant System leakage exceeded the 1 gpm limit.
PORC Action #2-73-053 Tne narrative attached to LER 78-62/lT stated:
e "At 1000 hrs. on Oct. 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 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 l
event was caused by misinterpertation of the requirements of the i
Technical Specifications.
Since the actual frequency of performance of the surveillance procedure was greater than that required by the Technical Specifications, 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 limit.s and this was accomplished at 0735 on October 18, 1978.
In addition, itrwas discovered that errors in inputting data to computer caused $ndicated' ur) identified leakage to
~
be greater than actually was occurring.
The appropriate personnel l --
..will be instructed on the requTrem~ents of. the ~ Applicable sectionsof the T.S. and the_ requirements':to~Tinmediate'ly invoke app.licable ^
~
action statements when the proJ sibns of limiting conditEns for i
operation are not. met. -Input JataEfor the computer-program which
- calculates unidentified leakage ha,s also been clarified."
4 4
2<
The PORC review and licensee management reporting of the above RCS leakage was perfon.ied as required by Technical Specifications.
The corrective actions were appropriate to correct the cause of the occurrence, j
however, they were not aggressively pursued.
PORC Action Item #2-78-053 required the Unit 2 Operations Engir.egr to insure the following is l
documented by Ops review of LER 76-62/lP(lT): :"The appropriate personnel will be instructed on the requirements of the applicable sections for j
the T.S. and the requirement to immediately. invoke applicable action i
statements wnen the provisions of the LC0's are not met."
The action l
iteu due date was designated as 11-20-78 by the Unit 2 Superintendent -
Technical Support.
Tne original du'e date.was 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 78-62 was initic ed by all appropriate Operations Department personnel including shift supervisors, shift foreman and control room operators.
- However, there was no indication of when these reviews were actually performed.
4L ~;.;' a ti' : C '" h PAI #2-78-053 was sianed by the PORC J 3
~
Chairman indicating all action was completedC
_W r LJca_i t
( }here were no regulatory requirements or licensee comitments for tompleting the corrective action for LER 78-62.within a specified period.)
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j METROPOLITAN EDISON COMPANY
'IHREE MILE ISLAND ICCLEAR-STATION T
UNIT #2 OPERATIONS REVID1 CCt4CTTEE
!EETING #290 October 17, 18, 19 and 20, 197S j
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Mmtines 4
Date Tine M:rnbers Items Discussed l
10/17 0900-0930 (p) R. P. Warren (V-C)
ICRC Items l
1345-1415 (p) R. W. Bensel Tests and Experiments l
(p) M. L. Benson
- (p) I. D. Porter
- (a) T. E. terck l
- (a) ' E. D. Showalter
- (a) D. B. Jenkins l
- (a) J. A. Brumer
- (a) J. R. Paules l
M. B. Bezilla D.
Haverkamp (USNRC) 10/18 1530-1700 (p) J. L. Seelinger (C)
PORC Items (p) R. P. Warren (V-C)
Plant Modifications (p) I. D. Porter '
Reportable Occurrences /
s (p) R. W. Bensel Violations (p) M. L. Benson
.)
- (a) T. E. terck s
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. Bensel
~
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- (p) R. W. Dubiel i
/
(a) W. J. Marshall (a) T. L. Mulleavy M. B. Bezilla 10/20 1430-1600 (p) R. P. Warren (V-C)
PORC Items (p) I. D. Porter (p) R. W. Bensel (a) T. E. terck (a) J. R. paules M. B. Bezilla fores:
(C)
Chairman (V-C) Vice-Chairman (p)
Primary Unit 2 PORC 1%mber (a)'
Alternate-Unit 2 PORC Fember as designated by the_.Chairmbr) or V_ ice-Chairman for this _neeting. -
- (*)
Indicates Part-Tine Attendance
~
~
~
~ _ _
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The requirements of Technical Specifications 6.5.1.3 f-and 6.5.l.5 were satisfied at all tine _s.
'Ihe PORC net formally for a total of 5.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> duri5g the week of October 16,197
row a
}f g Yeeting #290 ~ _ _.
October 17, 18, 19 and 20, 1978
'~
_ ests and Experiments _
T g
III.
Test Promdures_
4 The following Test /Special Procedure " Partial Test Results", 40% Plateau, 1.
j were reviewed and reemmended for approval:
l f
Test /Special Procedures TP2.11/1
~
TP271/4 (Petest)
'IP500/3 TP000/7 TP800/14 TP800/23 SP800/8 SP800/21 IV.
Tech Specs /Licensina Items None V.
Plant Modifications Change edification 2-0140 was reviewed and the PORC has determined that this Furthernere, this-CM 04 does not constitute any unreviewed safety questions.
].'
was recmtrended for Uhit Superintendent approval.
VI.
Reportable Occurrences / Violations _
NR-P-2A Shaft Failure.
(See Attachment'One)
(Pailure 'Ib Invoke The LCO, action b, of T.S. 3.4.6.2) }
m l LER 78-62/lP(lT)
PORC has reviewed this incident and determined it to be prompt reportIble inaccordance with T.S. 6.9..'. 8.b. _ (See Attachment Two)
VII.
Plant Operations Various numbers of the PORC attended the FOD where plant operations were reviewed, discussed and evaluated.
Various nembers of the PORC also aided and assisted in reconinending future activities to the Unit Superintendent.
VIII.
Soeefal Paviews and Investigations _
W mm b
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i Metropolitan Edison Cornpany fy' Post Of fice Box 480 d
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Middletown Pennsylvania 17057 a
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717 944 4041 I
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October 19, 1970
)
1 Mr.-Boyce H. Grier.
.j Director of Regulatory Operations Region I-I Nuclear Regulatory Commission 631 Park Avenue i
King of Prussia, PA 19406 Operatino License:
DPR-73 Docket:
50-320
Subject:
Reportable Occurrence No. 78-62/1P i
l
, y
Dear Mr. Grier:
-l i
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 hours0.0177 days <br />0.425 hours <br />0.00253 weeks <br />5.82165e-4 months <br /> on October 19, 1978.
' [;
- )
A situation considered reportable under technical specification 6.9.1.8.b l
was discovered at 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> on October 19, 1978, when it was determined l
that the limiting condition for operation (LCO), action b, for T.S. 3.4.6.2 3
1 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).
l This event occurred due to personnel errors in interpreting both the LCO j
W and surveillance performance requirements of T.S. 3.4.6.2.
1 Unidentified leakage was reduced to T.S. limits at 0735 on 10-18-78.
Further l
details and corrective action will be discussed in 'the followup report.
f i
J.L. Seelinger -
l Unit 2. Superintendent /
Technical Support i
JLS:bli
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ib-Metropohtan Edison Company is a Member of the Genera! Pubic U: sties System
~
METROPOLITAN EDISON COMPN 4Y-
'MEE MLLE ISLNID NUCLEAR STATION
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UNIT #2 OPERATIONS REVID4 CJrfurni,
)
MEETING H292 October.30 and 31 and November 1, 2 and 3,.1978
.O I.
t1eetinas Date Tine t$ embers Items Discussed
.1 10/30 1730-1800 (p) J. L. Seelinger (C)
- Reportable occurrences / )
(p) R. P. Warren (V-C)
Violations (p) R. W. Bensel
~
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(a) W. J.Lels (a) T. - E. ftrck i
10/31 1300-1330
- (p) J. L. Seelinger (C)
FORC Items 1800-1830 (p) R.. P. Warren (V-C)
Drergency Plan /Procedur!
(p) R. W. Densel
- (p) I. D. Porter
- (a) T. E. ftrck
- (a) M. L. Benson j
- (a) J. A. Brumur I
11/1 0900-0930 (p) J. L. Seelinger (C)
PORC Items (p)
R.' P. Warren - (V-C) q (p) I. D. Porter 1
(a) D. B. Jenkins -
(a) T. E. terck g
11/2 1630-1730-(p) J. L. Seelinger (C)
PORC Items 2200-2230 (p) J. F. Hilbish (V-C)
'Ibch Specs / Licensing It1 (p) R. W. Dubiel Plant Modifications i
- (p) R. E. Sieglitz Reportable. Occurrences,
- (p) R. P. Warren Violations
- (p) J. R. Floyd Security Plan /Procedur('
' * (p) I.
D.. Porter Energency Plan /Procedw i
- (a) D. B. Jenkins
]
M. B. Bezilla-11/3 1530-1615 (p) J. F. Hilbish (V-C)
PORC Items (p) I. D. Porter.
Plant Modifications (p) R. W. Bensel '
(a) T. E. ftrck (a) J. D. Lawton M. B. Bezilla NOl'ES:
(C)
Chairman (V-C) Vice-Chairman
.(p)
Primary Unit 2.PORC Mamber
~
~ _
[a).
AlternatetUnit 2 PORC Member as designated by t
the Chaidnan or Vice-Chairman for this mee' ting.
5 {*).
~ Indicates Part-Tine Attendance
~
hherequirementsofTebicalSpecificati6ns6d.1.3'
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end 6.5.1.5 were satisfied at all tirres.
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Th3 PORC met formally for a} total of 4.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />.during the' week of October 30, 1978.
j.
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Page 3 Pteting #292 g
October 30 and 31 and Novenber 1, 2 and 3,197{
j 1
f V.
Plant redifications
- 2J0137, #2-0157, N2-0172, #2-0179, #2-0189 and j
Change tbdifications #2-0104~,'PORC has determined that none of those cms
)
- 2-0201 were reviewed and the constitute an unreviewed safety question.
Furthermore, the PORC rec.cmunds 1
these 04s for Unit Superintendent approval.
l l
" ~
VI.
Reportable Occurrences / Violations I
PORC Review of NCR 78-171 - (Functional Fire Barriers)
(See Attachnent Two) l IIR 78-61/3L (Pailure To Satisfy The Requirements For Usino The Special' Test Exception Of T.S. 3.10.1)
PORC has reviewed and concurs with the response tcing forwarded to 1400A 1
inregard to IIR 78-61/3L.
(See Attachnent Three) g (Failure 'Ib Invoke The IJDO, action b, of T.S. 3.4.6.2),
LER 78-62/lP(lT)
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t DORC has reviewed and concurs with the response being forwarded to 1430A inregard to LER 78-62/lP(lT).
(See AttachTent Four) g 1
i VII.
Plant Operations-l E5 Various nembers of the PORC attended the POD where plant operations were reviewed, discussed and evaluated.
Various members of the PORC also aided and assisted in reconnending future activities to the Unit Superintendent.
l VIII.
Special Reviews and Investigations None l
IX.
Security Plan / Procedures l
Procedure Chance Recuests 1.
The following Procedure Change Request was reviewed and recommended for Unit Superintendent approval:
't 78-789 i
X.
Eneroency Plan / Procedures
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_Proced'ure_ Chance Reauests 1.
The~following Procedurs Cliangh Requests were reviewed and reccmnended for -
7 Unit Superintendent-approval:
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Ll METROPOLITAN EDISON COMPANY
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l POST OFFICE BOX 480 MID D LET OW N. PENNSYLV ANI A 17057
. TELEPHONE 717 944 4041 l
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MR. G.J. TROFFER I
SUBJECT:
UtlIT 2 LICEt1SEE EVENT REPORT 7p_gpf37 1.
Subject report is forwarded.
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J.L. Seelinger PORC Chairman TMI-2
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J.J. Barton R.M. Klingaman J.P. O'Hanlon ILB. Ba: illa G.A. Kunderr D.M. Shovlin R.W. Dubiei /
L.L. Lawyer Control Room Unit 2 J.R. Floyd J.B. Logan GRC Secretary J.G. Herbein T.A. Mackey Office File J.F. Hilbish v G.P. Miller Training Department Preparer James R. Stair
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LICENSEE EVENT REPORT CoNTr.ot stock: I I
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EVENT DESCRIPTION AND PROBA8LE CONSEQUENCES h o 1,1 lDuring performance of surveillance trocedure 2' 01-3D1 en Octebe-1o,otA 3
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Licensee Drent Report
- 27 Cause Description and Conective Actions - Cont'd limits at 0735 en 10-18-78.
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NARRATIVE TO 1.ER ' 7 8-62 /1T t
a At 1000 hocrs on October 19.1978.(wh11e perf orming Surveillance Procedure.
2301-3D1, it was deter =ined that data obtained subsequent to ' the -last recorded acceptable surveillance perf ormance at 1935 on 10-16 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 spin.
l This event was caused by misinterpretation of the requirements'of the T.S.
Since the actual' frequency of. perf ormance L of the' surveillance procedure was l'
greater than that required by the T.S.,
it was not clear to the personne1' O
involved as to.which set of data taken came within the T.S. requirements
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'and when the time. requirements:of the action = statement were applicable.
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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-p'ortion of this. leakage to be identifed leakag's 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 inputine da ta to -the' computer caused indicated unidentitiec. Leakage to be crescer ekan aerunliv was occurring.:
f' The appropriate personnel vill be instructed on.the requirements of-the d
applicab.Le sections of the T.S.. and the requirement to immediate1Y invoke l
A applicable action statements when the provisions of the LCO's are not met.
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Input data for the computer program which calculates unidentified leakage has also been clarified.
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METROPOLITAN EDISON 024PANY
'IHREE MILE ISLAND NUCLEAR STATION UNIT #2 OPERATIONS REVIEW CCrNIITEE MEETING #79-10 l
terch 5, 7, 8 and 9, 1979
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I.
Wetinas e
Date Time Manbers Item Discussed 3/5 1030-1130
- (p) G. A. Kunder (C)
PORC Items I
1500-1600 (p) R. P. Warren (V-C)
PORC Action Items q
(p) R. W. Bensel i
- (p) I. D. Porter l
(a) J. D. Lawton j
(a) D. B. Jenkins
- (a) D. L. Good M. B. Bezilla 3/7 1030-1100 (p) R. P. Warren (V-C)
PORC Items (p) I. D. Porter I
(p) R. W. Bensel (a) T. E. terck (a) D. B. Jenkins 3/8 1315-1500 (p) G. A. Kunder (C)
PORC Items (p) R. P. Warren (V-C)
Tech Specs /Li nsing Items; (p) I. D. Porter (a) T. E. Morck (a) J. R. Paules M. B. Bezilla
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3/9 0930-1030 (p) G. A. Kunder (C)
PORC Items (p) I. D. Porter (V-C)
Feportable Occurrenms/
(p) R. P. Warren Violaticns (a) T. E. terck PORC Action Items (a) T. A. O' Canner
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M. B. Bezilla NCTES:
(C)
Chairman (V-C) Vice-Chairman (p)
Primry Unit 2 PORC mmber l
(a)
Alternate Unit 2 PCRC Murber as designated by the Chairman or Vice-Chairman for this meeting.
(*)
Indicates Part-Tine Attendance l
'Ibe requirements of Technical Specifications 6.5.1.3 and 6.5.1.5 were satisfied at all tim s.
'Ibe PCRC mt formally for.a total of 5.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> during the week of March 5,1979.
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Mmting #79-10 terch 5, 7, 8 and 9, 1979 VI.
Reportable Occurrences / Violations PORC Review Of NCR 78-179 For Deportability n
(See Attachnent 'IWo) i LER 79-012/3L (Degradation Of Fire ' Barrier ~ Penetrations Constructed Of Firewall - 5(i l
PORC has reviewed this item and determined that it constitutes a thirty day report 0 inaccordance with T.S. 6.9.1.9.b.
(See Attachment 'Ihree)
VII".
Plant Operations Various nerbers of the PCRC attended the POD where plant operations were reviewed, discussed and evaluated. Various menters of the PORC also aided and assisted.in rec.umuuding future activities to the Unit Superintendent.
]
VIII.
Special Revies.,; tnd Investigations j
None IX.
Security Plan / Procedures None i
X.
Eneroency Plan / Procedures
(
None XI.
PORC Action Items.
j
'Ibe follcWing 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)
PAI 2-79-021 PAI 2-79-022 (See Attachnent Four)
XII.
Other 1.
PORC reviewed all of the items covered' in Sections II through VI and IX and X and ccocluden that ncne of the' items constituted an Unreviewed Safety
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J Serial # PAI 2-78 053 r
Responsible Individual:
W. Marshall-W. Fels
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TMI-2 PokC ACTION ITEMS 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 t
l II.
Title /
Description:
Failure To Invoke T.S. 3.4.6.2 (RCS Leakage Spec) l Ill. Commitm'nts/ Action Recuired:
e WJM - Insure the following is documented by Ops review of.LER 78-62/IP (IT):
"The appropriate personnel wi.11 be instructed on the requirements of the applicable sections for the T.'S. andithe reqdiremehtito immsdistb1'y'invote' pe/efe pa applicable action statements when the provisions of the LC0's are not met."
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..WJF--Shor-t-wr4-teup-er the #elleM n;-
i ainnut a2+n Snr +he enm79ter nrngrem 1.,4 4 c h - c 31 cg13 te: "ridentiried le & ge.
has a.lso been-cL'* m d."
e.
3 Due Date:
11-20-78 t
A/
IV.
Documentation of Completion (Procedure Revised, PCR!, T
- , WR Number, tc.)
(Attachments as necessary)
'See attached signed-off sheet.
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All Action Completed
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PORC% Chairman TMI-2 Date
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cc: Station Superintendent.
Dnit 2 Superintendent
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Responsible Individual
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.c THI-2-PORC ACTION ITEM
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p PAI # 2 C d _
Due Date: //-E#
New Due Date: t2-if-7 3 l
i Reason for' Extension:
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,'l1 Submitted By:
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Concurred:
P(RC Chainnan
.P TMI-2 t
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- Distribution:
H. B.'Bezilla
=J Responsible Person (waQ1).
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DOCUMENT REVIEW j
g UNIT #2 CONTROL ROOM 78 REVIEW BY
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I DOCUMENT NO.
G8-78-la 2.
REVISION N0.
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DOCUMENT TITLE Af
/EAcA6a H
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' SHIFT SUPERVISORS W.H. Zewe-d
- J. R. Floyd
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W. J..starshall L W e J.J. Chwastyk
.'P.' Bryan
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SHIFT FOREl.~N_
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A.W. Hiller N
l, C.D. Adams-fA
. c-R,.S. Hutchison K.R. Hoyt u H,
- c. L. Cow, -
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W.T. Conaway ugM F.J. Scheimann S Lt g
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'E.R. Frederick 8N L.O. Wright o
.C.C. Faust
/11,/I M.S. Coleman M/C-
-H.A. McGovern LL/'
D.I. Olson
. // W J T.F. Illjes r
.R.R.'Booher _ UDb E.D. Hemmila 4 KV L H.W. Ha.rtman
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J.M.' Kidwell. ffW 1
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'C.F. Mell 1
J.R. Congdon
_n's L-H D. Phillippe. l
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M.V Cooper.
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L.y. Germer
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