ML20204J868

Rept on Discussions W/Employees Re Documents on Leak Rate Testing Practices.Prior to 860328 Personnel Discarded Invalid Test Results & Tests Ran Every 8 H.W/Certificate of Svc.Related Correspondence

ML20204J868
Person / Time
Site:	Three Mile Island
Issue date:	08/05/1986
From:	Blake E GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
References
CON-#386-252 86-519-02-SP, 86-519-2-SP, LRP, SP, NUDOCS 8608110218
Download: ML20204J868 (9)

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USN 3 @E -7 40:17 August 5, 1986 KT b ??.l?Y UNITED STATES /.QFIAMEkICA NUCLEAR REGULATORY COMMISSION BEFORE THE PRESIDING BOARD

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i In the Matter of )

i ) Docket No. LRP j INQUIRY INTO THREE MILE )

ISLAND UNIT 2 LEAK RATE ) ASLBP No. 86-519-02 SP

DATA FALSIFICATION )

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GPU NUCLEAR CORPORATION'S REPORT ON DISCUSSIONS WITH NUMEkOUS EMPLOYEES CONCERNING DOCUMENTS ON TMI-l LEAK RATE TESTING PRACTICES GPU Nuclear and Numerous Employees have exchanged in several pleadings their views on the admissibility of documents related to leak rate testing practices at TMI-1. GPU Nuclear has opposed Numerous Employees' related requests that the Presiding Board admit into evidence an OI Report and portions of NUREG-0680, Supp. No. 5, identified by Numerous Employees. Numerous Employees have grounded their requests on a desire for an historical perspective regarding leak rate testing practices at TMI-l and the opportunity to compare the Staff's and the

commission's handling of TMI-1 leak rate practices with whatever findings are made by the Board as to such practices at TMI-2.

GPU Nuclear has based its opposition to Numerous Employees' requests.to date on the potential unnecessary and inappropriate 86061%$$

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expansion of this proceeding from TMI-2 into TMI-1 that could conceivably follow if Numerous Employees' requests were approved.

GPU Nuclear and Numerous Employees have discussed their

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respective positions with an eye on attempted resolution of their differences. The result of these discussions is that if the Presiding Board agrees with Numerous Employees that an historical perspective on TMI-l leak rate testing practices should be included in the record, GPU Nuclear is prepared at hearing to offer into evidence as admissions requested by Numerous Employees those statements in Attachment A to this Report. Numerous Employees for their part would withdraw their request for admission of those documents regarding TMI-1 which they identified in their July 14, 1986, filing with the Presiding Board, if GPU Nuclear's proffer is accepted by the Board and on the understanding that the Staff (and not the Board) is to "make recommendations to the Commission regarding what action, if any, should be taken." CLI-85-18, 22 N.R.C. 877, 883 (1985). Based on those understandings, GPU Nuclear and Numerous Employees generally would oppose further attempts to broaden the scope of this proceeding into wholesale review of TMI-l leak rate testing practices.

Both GPU Nuclear and Numerous Employees are prepared to discuss this matter further with the Presiding Board at the

o Prehearing Conference on August 25, or sooner if the Board desires. Counsel for Numerous Employees concurs in this Report.

Dated: August 5, 1986 Respectfully submitted,

/ Ernest L. Blake, Jr.

John N. Nassikas III SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1084 Counsel for GPU Nuclear Corporation l

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l ATTACHMENT A

1. It was common practice in the period prior to March 28, 1979, for TMI-l control room personnel to discard test results that were deemed invalid.

2. The THI-1 control room computer would calculate leak rates on the basis of a 1-to-8 hour time interval. Normally, a leak rate test interval of one hour was selected. All but two of the questionable leak rate tests evaluated in the Region I inspection of TMI-l leak rate surveillance testing conducted prior to the investigation were conducted with a 1-hour duration. Provided the plant is maintained in a steady-state condition for the entire test period, the error inherent in the leak rate calculation is reduced as the test duration is extended.

, 3. While the TMI-1 Technical Specifications required that the RCS leak rate be determined every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, actual leak rate tests were conservatively run once per shift (every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) as a matter or routine.

4. The TMI-l RCS leak rate procedure, SP 1303-1.1, prohibits the addition of chemicals during the test, although the procedures did not specifically identify hydrogen as a chemical.

5. Log entries were not normally made in the TMI-1 control room operator's ("CRO's") log for hydrogen additions.

6. There were legitimate operational reasons why hydrogen was added to the TMI-1 RCS makeup tank periodically. The frequency of addition varied with plant conditions.

7. The TMI-l leak rate surveillance procedure, SP 1303-1.1, required operator-induced inventory changes (e.g., water additions) to be taken into consideration in the leak rate test calculations.

8. Feed-and-bleed operations are usually done at TMI-l to change the RCS boron concentration and the amount of coolant removed is normally equal to the amount added. Performing this operation during a RCS surveillance test would tend to reduce the. accuracy of the leak rate test results; however, it would not be an effective means of reducing the measured leak rate unless the amount of coolant added exceeded the amount removed.

9. TMI-1 Technical Specification Table 4.1.2, " Minimum 4 Equipment Test Frequency," required that RCS leakage be determined daily when the RCS temperature was greater than 525' F. Surveillance Procedure 1303-1.1, "RC System Leak Rate," was the approved procedure that governed how the leak rate tests were to be conducted.

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10. The RCS leak rate test procedure utilized at TMI-l during the year prior to March 28, 1979, contained several inadequacies. These would, in most instances, have calculated leak rate values that were less than the actual leak ratets. Because of these errors in the test calculations, the surveillance test records frequently showed negative leak rate results.

11. There was no formal guidance provided by TMI-1 management for determining whether a leak rate test was classified as valid or invalid. Either large positive leak rates that were not representative of what other plant instrumentation indicated or large negative leak rates were routinely considered invalid. When an invalid leak rate test result was obtained, the operators would start a new leak rate test calculation. When a valid leak rate result was obtained, the invalid test was thrown away. Invalid tests were not recorded in the CRO's log; the reasons why the tests were considered invalid were not written in the remarks section of the data sheet; problems encountered while performing the tests were not recorded on " Exception and Deficiency" reports; and test results were not maintained on file for a period of five years. The TMI-1 operators indicated that

. invalid leak rate tests were not indicative of actual plant conditions and, because the information obtained from the computer was in error, they did not believe it was required to be kept.

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12. It is apparent from interviews conducted with the TMI-l control room operators that the performance of RCS leak rate tests at TMI-l was considered mundane and repetitive and that the actual performance of the tests was approached in a very perfunctory manner.

13. TMI-l used a temperature versus RCS density conversion table in its computer programs that only went up to 582* F. This was not a problem for Unit 1 because RCS temperature rarely exceeded 582* F.

14. At TMI-1, RCS losses to certain connecting systems such as the RCDT were not considered leakage and, thus, were subject to the limit for leakage plus losses of 30 gpm.

15. The TMI-l limit for unidentified leakage was 1 gpm, after subtracting an evaporative loss factor of 0.51 gpm.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE PRESIDING BOARD

)

In the Matter of )

1

) Docket No. LRP 4

INQUIRY INTO THREE MILE )

ISLAND UNIT 2 LEAK RATE ) ASLBP No. 86-519-02 SP DATA FALSIFICATION )

)

CERTIFICATE OF SERVICE I hereby certify that on August 5, 1986, I served the foregoing "GPU Nuclear Corporation's Report on Discussions with Numerous Employees Concerning Documents on TMI-l Leak Rate Testing Practices" by delivering a copy thereof by hand on those persons identified with one asterisk and by mailing a copy thereof first class, postage prepaid, on the following:

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• Administrative Judge James L. Kelley, Chairman l Atomic Safety and Licensing Board Panel

+ U.S. Nuclear Regulatory Commission

{ Washington, D.C. 20555 t

i

• Administrative Judge Glenn O. Bright Atomic Safety and Licensing Board Panel l U.S. Nuclear Regulatory Commission Washington, D.C. 20555

{

• Administrative Judge Jerry R. Kline Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission l

Washington, D.C. 20555 i

• Jack R. Goldberg, Esq. l Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

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Docketing and Service Branch (3)

U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Harry H. Voigt, Esq.

James W. Moeller, Esq.

LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.

Suite 1100 Washington, D.C. 20036 Smith B. Gephart, Esq.

Jane G. Penny, Esq.

Killian & Gephart 216-218 Pine Street Box 886 Harrisburg, Pennsylvania 17108 James B. Burns, Esq.

Isham, Lincoln & Beale Three First National Plaza Suite 5200 Chicago, Illinois 60602 Michael W. Maupin, Esq.

Hunton & Williams P.O. Box 1535 Richmond, Virginia 23212 Mrs. Marjorie M. Aamodt Box 652 Lake Placid, New York 12946 and J

Mrs. Marjorie M. Aamodt 200 N. Church Street I Parkesburg, Pennsylvania 19356 c

/3ohn N. Nassikes GI 2

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