IR 05000289/1984037

Insp Rept 50-289/84-37 on 841119-21.No Violation or Deviation Noted.Major Areas Inspected:Operational Surveillance Program Associated W/Emergency Feedwater Sys & Followup to Previous Insp Findings

ML20140E585
Person / Time
Site:	Three Mile Island
Issue date:	12/20/1984
From:	Bettenhausen L, Vito D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20140E583	List: IR 05000289/1984037 ML20140E577
References
50-289-84-37, NUDOCS 8501110155
Download: ML20140E585 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /84-37 Docket No. 50-289 License N DPR-50 Priority -

Category C Licensee: GPU Nuclear P. O. Box 480 Middletown, Pennsylvania 17057 Facility Name: Three Mile Island Nuclear Station, Unit 1 Inspection At: Middletown, Pennsylvania Inspection Conducted: November 19-21, 1984 Inspectors: / 7 D. J//Vito, Reactor Engineer 'da t'e Approved by: N[ p L. H. Bettenhausen, Chief,

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/MM date

Test Programs Section Inspection Summary: Inspection on November 19-21, 1984 (Inspection Report N /84-37)

Areas Inspected: Routine, unannounced inspection of the operational surveill-ance program associated with the Emergency Feedwater System, and followup to previous inspection finding The inspection involved 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> onsite by one region based inspecto Results: No violations were identifie *

PDR ADOCK 05000289 0 PDR

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DETAILS

' Persons Contacted

.GPU-Nuclear-J. Bashista, Mechanical Engineer

• R.: Knight, Licensing Engineer <

NRC Personnel

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.R. Conte, Senior Resident Inspector

• F. Young,. Resident Inspector

• Denotes those present at exit interview on November'21,198 .- Followup on Previous Inspection Findings

'(Closed) Inspector Followup _ Item (289/84-11-03). This item refers to the 2 need for-licensee _ clarification of,some terms and phrases used in the Syn'ptom-Oriented Abnormal Transient (AT0G) Procedures. The inspector

. reviewed the latest. revisions of Abnormal Transient Procedures ATP 1210-5,

-0TSG Tube Leak / Rupture, Revision 4, 8/28/84; ATP'1210-6, Small Break LOCA Cooldown, Revision 3, 8/28/84, and ATP 1210-9,.HPI Cooling - Recovery from-Solid Operations, Revision 4, 8/28/84, for clarification of the isolation criteria for the Core Flood Tanks. In addition to the requirement of_ade-

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-_quate subcooling margin and an RCS. pressure of greater than 700 psig, the licensee has added a phrase _to the' procedure step which requires that the operator also assures control-of RCS pressure and inventory. The inspec-tor noted that this additional phase provided sufficient clarification'and_ ~

would be helpful in assuring the existence of stable plant conditions prior to ' isolation of:the-Core Flood Tank The inspector also reviewed GPU' Nuclear Memorandum 3210-84-0308 dated July -

'19, 1984, from M. J. Ross, Manager,_ Plant ~ Operations to the TMI-1 licensed-operators. The intent of the memorandum was to further define the concept

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of " Excessive" Primary to Secondary Heat Transfer as it is referred to in-the ATOG procedures. Previous interviews with the operators had indicated some confusion in the~ definition'of this term. The memorandum emphasized-

-that excessive primary to secondary heat _ transfer is characterized by an inability to control the cooldown rate to within the required limits. The

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handling of this excessive cooldown rate will depend on the rate of cool-

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down and the rapidness.of operator response. The inspector was satisfied

~with the clarifications._provided in-the_ memorandum..'The inspector also

, verified that the memorandum had been sent to the plant training depart-

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ment fo.- inclusion in the operator training progra Based on these findings, this item is closed, w

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"; 2 Emergency Feedwater System Operational Surveillance 3.1 Documents Reviewed

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NUREG 0680, Supplement No. 5, TMI-1 Restart, Section 5.4, Emer-gency Feedwater Pump Surveillance Tests

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Surveillance Procedure SP 1300-3F A/8, Motor Driven Emergercy Feedwater Pump Functional Test / Valve Lineup and Operability Test, Revision 17, 7/11/84

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Surveillance Procedure SP 1300-3G A/B, Turbine Driven Emergency Feedwater Pump Functional Test and Valve Operability Test, Revision 15, 1/24/84

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Surveillance Procedure SP 1300-3R, Inservice Testing of Valves During Shutdown and Remote Indication Check, Revision 13, 8/4/84

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Surveillance Procedure SP 1302-6.17, Emergency Feedwater Initia-tion - Loss of Feedwater, Revision 3, 9/28/84

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Surveillance Procedure SP 1303-11.39, Emergency Feedwater Pump Auto Start, Revision 5, 6/13/83

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Surveillance Procedure SP 1303-11.42, Emergency Feedwater Flow Test from Condensate Storage Tank, Revision 1, 6/29/83

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Surveillance Procedure SP 1303-11.53, Emergency Feedwater Flow, Revision 3, 1/5/84

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Operating Procedure OP 1106-6, Auxiliary Systems Operating Procedures - Emergency Feedwater, Revision 36, 6/8/84

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Letter July 10, 1984, H.D. Hukill to J. F. Stolz, Inservice Testing of Pumps and Valves (IST) Program Submittal ,

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Letter October 23, 1984, J. F. Stolz to H. D. Hukill,- NRC Review of THI-1 IST Program

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ASME Boiler and Pressure Vessel Code, Section XI, Division I, 1980 Edition and Addenda through Winter, 198 TMI-1 FSAR, Section 10.6, Emergency Feedwater System

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TMI-1 Technical Specifications (various sections)

3.2 Scope of' Review The inspector reviewed the documents listed above to determine the technical adequacy of the Emergency Feedwater System (EFW) surveill-ance program and compliance of the program with the Technical Specif t- '

cations and other regulatory requirements. The surveillance proce-

~dures were reviewed for clarity and for conformance with the in-service testing requirements of the ASME Code.

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3.3 Procedure Review The Emergency Feedwater System surveillance procedures listed in Sec-tion 3.1 were reviewed for technical adequacy and procedural clarit The review was inclusive of all the pumps and valves associated with the EFW system. As such, the review of the EFW pump surveillance tests fulfills the requirements stated in NUREG-0680, Supplement 5, Section 5.4.2'for NRC review of the EFW pump surveillance procedures prior to TMI-1 restar The review of the EFW system surveillance procedures revealed the following: The inspector found no instances of procedural discontinuity; i.e., procedures could be followed logically from beginning to end and valve lineups and procedural valve manipulations occurred in a logical fashio All valves which require testing were addressed in the proce-dures. However, EF-V3, the Emergency River Water Suction Source Check Valve was not tested for full stroke capability. Also, MSV-10A and MSV-108, Steam Supply Valves to the Turbine Driven EFW Pump Turbine, were not stroke time tested. These discrepan-cies will be addressed later in a discussion of the inservice testing progra The inspector found no instances in the procedures which would effect a simultaneous isolation of both EFW trains. In addi-tion, the procedures contain warnings and reminders to assure the availability of the EFW train which is not being tested, when necessar Provisions have been made for recording the necessary test instrument readings. These include pressures, differential pressures, vibration readings, and bearing temperatures. The pump surveillance procedures also record the flow rate. However, flow rate is not a test variable as this is a fixed resistance system. Valve stroke times are also recorded, as appropriate, The EFW pump surveillance tests do not indicate any attempts to control both independent and dependent variables simultaneousl This can be more readily verified when the tests are actually performe Procedure criteria for establishing revised reference values when a reference value or set of values has been affected by the repair or servicing of an EFW pump are acceptable and in accord-ance with the requirements of Section XI of the ASME Code. The procedures also require that justification for revising a set of reference values shall be documented in the Technical Specifica-tion Surveillance file of the affected EFW pum I . ..

Based on these findings the inspector concluded that, with the excep-tion of the IST discrepancies related to valves EF-V3, MSV-10A, and MSV-108, the EFW system surveillance testing procedures are techni-cally accurate and are in compliance with the applicable testing requirements. The use of these procedures should in no way compro-mise or degrade the operability of the EFW syste .4 EFW System Inservice Testing Requirements The inspector reviewed the licensee's inservice testing (IST) program as it related to the EFW system in conjunction with the EFW system surveillance procedures to determine if the testing designated in the IST program was indeed being performed as part of the test procedure The inspector also reviewed the EFW system IST program and surveill-ance test procedures for conformance with subsections IWP and IWV of Section XI of the ASME cod With the exception of the valve testing discrepancies noted below, the inspector found the IST program and the surveillance testing pro-cedures for the EFW system to be in conformance with the procedural, measurement, records, and test results evaluation requirements of Subsections IWP and IWV of Section XI of the ASME Cod The noted discrepancies are: Subsection IWV of Section XI of the ASME Code states that check valves may be part-stroke exercised during plant operation if full-stroke exercising is not practical but shall be full-stroke tested during periods of cold shutdown if it has been longer than 3 months since the last full-stroke functional test. The Emergency River Water Suction Source Check Valve EF-V3 is only partially stroke tested in SP-1300-3G A/B, Turbine Driven EFW Pump Functional Test and Valve Operability Test. This discre-pancy was noted in the NRR review of the TMI-1 IST Progra (Letter of 10/23/84, J. F. Stolz to H. D. Hukill). The licensee has been given 120 days from the-date of this letter to revise the procedures and the TS to reflect the IWV requiremen . The inspector noted that although the IST program states that Turbine Driven EFW Pump Steam Supply Line Valves MSV-10A and MSV-10B will be full-stroke tested and stroke timed, the step calling for stroke timing of these valves could not be located in any of the E.CW system surveillance procedures. A licensee-Mechanical Engineering Department representative stated that this discrepancy had already been identified and that a proce-dure change was in process. _ The process change had not received approval by the completion of this inspectio ~

The resolution of these items will be reviewed during a future inspec-tion of the licensee's IST program. These items are collectively designated as Inspector Followup Item 50-289/84-37-01.

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3. 5' EFW Systerr. Technical Specification Surveillances As'an independent check of the comprehensiveness of the IST program and related procedures, the inspector reviewed the TMI-1 Technical-Specifications to determine whether TS required testing of the EFW

- system was addressed in plant procedures. .The inspector found that all of.the testing required by the_TS was addressed in the operating procedure and surveillance procedures related to the EFW system. The procedures and related TS are as follows:

Procedure T5 Subject OP 1106-6 3.4. EFW Train Availability 3.5. EFW Flow Accident Monitoring Instrumentation Availability

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SP 1303-11.53 Table 4.1-1, EFW Flow Instrumentation Item 50 Calibration SP 1303-11.42 4.9. EFW Flow Test from CST to Steam Generators from Motor Driven EFW Pumps SP 1303-11.39 Table 4.1-1, EFW System Starting SP 1302-6.17 Item 51 Instrumentation Checks SP 1300-3F A/B 4. IST of EFW System Components, SP 1300-3G A/B 4. System Operability Verifica-SP 1300-3R tion The inspector concluded that the existing EFW system operating and surveillance procedures are sufficient to perform those actions-required by the. Technical Specifications, with the_ exception of the IST. program discrepancies noted in Section 3.4 of this repor .0- EFW System Operation After Restart The. inspector reviewed the EFW System operating-procedure (OP_1106-6) to ,

determine whether or not:the licensee commitment to lock open the recircu-11ation line. valves during' operation had been addressed. This commitment was made in a-. letter of March 22,1983 from H. D. Hukill to J. F. Stolz documenting the amount of flow which could be delivered to the steam gen-erators in the event of a rupture in the non-seismically designed portion-of the recirculation line. The licensee has stated specifically in OP-1106-6 that.the automatic recirculatio'n-valves (EFV-8A,B and C) are to be L blocked open'with mechanical blocks and lifted leads to satisfy the re-quirement. The contrals for EFV-8A,B and C are to be upgraded to Safety-Grade:during the first refueling' outage after restart. -The inspector ha .no further' questions.at this tim .-

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5.0 QA/QC Involvement The inspector inquired as to the amount of QA/QC involvement in the EFW system surveillance program. The licensee informed the inspector that although QC monitoring of EFW system surveillance has been planned, in-volvement at this point in time was minimal. The inspector acknowledged the licensee's statements and stated that a more in-depth review of QA/QC involvement in this area would be performed when the testing is performe ~ Tours The inspector made several tours of the facility to observe work in pro-gress and general housekeeping. No unacceptable conditions were identi-

-fie .0 Exit Interview A meeting was held on November 21, 1984 to discuss the scope and findings of the inspection as detailed in this report. At no time during the inspection was written information provided to the license .

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