ML20204F825

Safety Insp Rept 50-289/87-06 on 870217-0303.Violations Noted:Sp 1302-5.10 Not Performed as Written in That Entire Instrument Loop Not Calibr at One Time & Design Calculation Revised W/O Review or Provisions for Review

ML20204F825
Person / Time
Site:	Crane
Issue date:	03/17/1987
From:	Blough A, Conte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20204F540	List: ML20204F536 ML20204F557 ML20204F825
References
50-289-87-06, 50-289-87-6, NUDOCS 8703260277
Download: ML20204F825 (47)

See also: IR 05000289/1987006

Text

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8

U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.

87-06

Docket No.

50-289

License No.

OPR-50

Licensee:

GPU Nuclear Corporation

P. O. Box 480

Middletown, Pennsylvania 17057

,

Facility Name: Three Mil'e Island Nuclear Station, Unit 1

Inspection At: Middletown, Pennsylvania

Inspection Conducted:

February 17 - March 3, 1987

Inspectors:

W. Baunack, Project Engineer

P. Bissett, Reactor Engineer

L. Briggs, Lead Reactor Engineer

D. Johnson, Resident Inspector (TMI-1)

J. Kaucher, Resident Inspectcr (Limerick II)

T. Kenny, Senior Resident Inspector (Salem 1 & 2)

S. Peleschak, Reactor Engineer (Entry Level)

D. Trimble, Resident Inspector (Calvert Cliffs 1 & 2)

,

F. Young, Resident Inspector (TMI-1)

Reviewed By

3--/ 7-'<P2

/L R~. Conte, Tea # Leader

Date

Approved By

/4

A/ 7 <P)

A. Bloupr(Senior Team Manager

Datt

Inspection Summary:

This special safety inspection (459 staff hours) was to assess licensee control

measures for overall readiness to start up TMI-1 after a scheduled five month

!

refueling outage.

The inspection included a design review of the Heat Sink

.

Protection System (HSPS), focusing on instri. ment and control aspects.

The

following functional areas were covered:

plant operations; maintenance; sur-

veillance; technical support, includins modification and test control; and

assurance of quality. Within each functional area, the team members assessed

the status and quality of:

the licensee meeting safety grade design for fiSPS;

procedure revisions as a result of facility modifications (including HSPS) and

B

PG

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Inspection Summary (Continued)

2

recent technical specification changes; quality assurance department involve-

ment in the outage; and, licensee prerequisite lists for startup. Licensee and

NRC outstanding items to remain open at the time of startup were assessed for

any impact on safety.

The adequacy of completed work as prerequisites for

Cycle 6 startup was also selectively reviewed.

Inspection Results:

The team noted that sufficient control measures existed to assure the safe re-

start of TMI-1. In all functional areas reviewed, the licensee's organization

appeared to be -dedicated and conscientious in assuring the readiness of the

facility and personnel for this startup. At the time of the inspection, com-

pleted maintenance and surveillance (except for new systems) demonstrated plant

readiness for startup in their respective areas. The quality assurance depart-

ment involvement in this outage was substantial.

The- team also noted a number of licensee initiatives that enhanced the overall

control of activities.

In the plant operations area, there was a dedicated

,

shift tachnical adviser providing interface support between that department and

engineering personnel.

Requalification examinations will be completed, along

with extensive training, for licensed operators on new modifications installed

during this outage. The licensee's extensive prerequisite list has an apparent

overall command and control effect on all licensee divisions to support the

TMI-1 division.

' As would be expected, a substantial amount of work remains to be completed.

Most significantly, a number of design analyses in the mechanical, structural,

electrical,'and instrument and control disciplines was needed to confirm the

fully safety grade configuration of the emergency feedwater system. ~There were

residual issues in the overall environmental qualification and fire protection

programs.

In the plant operations area, system walkthroughs and valve lineups

had not started but were scheduled to be completed. Updated "as-built" config-

uration documents, such as drawings, were needed to be placed in the control

room. Based on the large volume of work remaining, the tentative startup date

appeared to be in jeopardy in the judgement of the team. The licensee empha-

sized that the startup date would be adjusted if plant readiness for restart

was not achieved when currently scheduled.

The team identified a number of items that were not specifically known to

licensee representatives.

The apparent failure to follow procedures in the

surveillance area was another example of the licensee's procedure adherence

problem for which the licensee was in the process of taking generic correction

action (paragraph 4.2.3).

The apparent failure to properly review and approve

an HSPS setpoint calculation was another example of a lack of atteation to

detail in the technical support area (paragraph 5.1.2.4).

A number of other

HSPS design analyses either were not well documented or it was not clear that

they would have been completed prior to plant startup without team identifica-

tion of the issues; e.g.,

seismic II over I study.

There appears to be a need

to enhance the operating procedures and labeling of cabinets for the HSPS.

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Inspection Summary (Continued)

3

There was one instance of operations department disruption of the smooth con-

duct of a preoperational test. This could have been precluded had there been

more forethought in the test preplanning and pre-implementation evaluation

stage.

In general, the test program was adequately performed and was identi-

fying design / installation errors as intended.

1

Careful management inve',vement and close attention to detail on the part of

personnel and their supervisors will be needed to assure the safe startup of

TMI-1.

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TABLE OF CONTENTS

Page

1.

-Introduction and Overview . . . . . . . . . . . . . . . . . .

1

2.

Plant Operations. . . . . . . . . . . . . . . . . . . . . . .

3

3.

Maintenance . . . . . . . . . . . . . . . . . . . . . . . . .

9

4.

' Surveillance . . . . .. . . . . . . . . . . . . . . . . . . .

12

5.

Technical Support (Modifications and Test Control). . . . . .

20

.

6.

- Assurance of Quality. . .

31

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7.

Previous' Inspection Findings. . . . . . . . . . . . . . . . .

37

8

Exit Interview. . . . . . . . . . . . . . . . . . . . . . . .

40

Attachment 1 - Persons Contacted

Attachment 2 - Detailed Activities Reviewed

.

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DETAILS

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1.0 Introduction and Overview

1.1 Background and Purpose

,

With the shutdown of TMI-I on October 31, 1986, the licensee com-

pleted the first cycle of operation since the TMI-1 restart and

entered a scheduled five month outage for refueling and extensive

facility modifications.

Significant modification work included up-

grading of the fire protection and emergency feedwater systems. Also,

a number of the restart commitments and TMI Task Action Plan (TAP)

items are due to be completed for this startup. In light of the out-

age length, significant licensee workload and s: ope of modifications,

Region I chose to perform a special readiness assessment team (RAT)

inspection at TMI-1.

-i

The purpose of the inspection was to assess the licensee's overall

readiness for startup after this extended refueling outage. The main

focus of the inspection was on the adequacy of licensee management

controls that would assure the resolution of technical and safety

issues prior to plant startup.

The team was well aware that the

plant would not be physically ready for operation at the time of this

inspection.

-1.2

Inspection Process

The team was composed mostly of experienced resident and region-based

inspectors assigned to TMI-1 and other Region I facilities. The fol-

lowing functional areas were reviewed:

plant operations; mainten-

ance; surveillance; technical support, focusing on modification and

preoperational testing control; and, assurance of quality, which

included certain training aspects.

An important part of this inspection was a detailed design review in

the Instrument and Control (I&C) area for the Heat Sink Protection

,

System (HSPS), the safety grade initiation and control system for the

'

emergency feedwater system.

From the design review, NRC staff fol-

i

lowup occurred on site regarding the HSPS installation and other

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functional activities.

This methodology was similar, but on a more

limited basis, to the first performance appraisal team inspection of

1986.

A number of general attributes were assessed by the team on a samp-

ling basis.

The status and quality of the safety grade design of HSPS to

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meet regulatory requirements and commitments.

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The status and quality of procedure revisions as a result of-

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facility modifications and recent Technical Specifications (TS)

amendments.

The status and completeness of licensee outstanding items lists

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for startup in the various functional areas.

Included in this

was an assessment of an impact on safety, if any, for these out-

standing items that would be left open at the time of startup.

Impact on safety of those NRC inspection findings that will be

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outstanding at the time of startup.

Quality assurance department

involvement

in the refueling

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outage.

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Overall adequacy of the licensee's prerequisite lists and start-

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up plans.

1.3 Safety-Grade Emergency Feedwater Background

Commission Order CLI 85-9 permitted THI-1 to resume operation subject

to the conditions imposed in the restart proceedings. _ Restart Condi-

tion 3(a) requires that prior to startup following Cycle 6 refueling,

GPU Nuclear Corporation shall upgrade the EFW system to provide

safety grade automatic control and to provide other system improve-

ments to include redundant control and block valves, automatic start

on Once-Through Steam Generator (OTSG) low level and upgrades _ of the

. main steam rupture detection system and the condensate storage tank

low-low level alarm to safety grade. This condition, along with the

associated hearing records and NRC staff safety evaluations, basic-

ally delineate the requirements that are embodied in Task Action Plan

(TAP) II.E.1.1 and b .E.1.2 of NUREG 0737.

The purpose of this review was to verify that the licensee incorpo-

rated NRC-imposed design objectives into licensee design packages /

documents and plant installation documents / records as required by the

Restart Condition 3(a).

A review of the NRC-imposed design objec-

tives was performed as part of NRC Inspection Report No. 50-289/

85-20. This report, coupled with past inspection reports, verified

the required design requirements had been incorporated in the licen-

see's design / installation documents.

Selected modifications

for

restart completed in 1985 were also verified to be in accordance with

the intended design and properly installed for restart.

Additional

required reviews to be completed were being followed as an unresolved

.

item (289/85-20-01).

This report focused on the design and installation of the HSPS por-

tion of safety grade emergency feedwater. Residual issues associated

with restart condition 3(a) are addressed in paragraph 7.2.

The NRC findings and conclusions are addressed below (Sections 2

through 7).

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2.

Plant Operations

2.1 Criteria and ' Scope of Review

To assess readiness in the plant operations area, the inspector re-

viewed the following items: (1) licenses mechanisms to identify work

to be completed; (2) listings of outswding work and administrative

controls for ensuring work completion; (3) status of incorporating

procedure changes resulting from the Hett Sink Protection System

(HSPS) modification and related technical specification changes; (4)

the technical adequacy of HSPS procedure changes; (5) training mate-

rial and training activities providea-to operators on HSPS; (6) the

interface of HSPS with the Integrated Control System (ICS); and, (7)

human factors placement of Emergency Feedwater System (EFW) valves.

The basic requirements for this area are TS 6.8 and ANSI 18.7-1976.

The HSPS modification was chosen for review because it was a major

activity completed during the outage with significant importance to

safe plant operations.

The inspector looked for evidence that all work necessary for startup

had been identified, was being adequately performed, and would be

completed on an appropriate schedule.

Principal documents reviewed included the "TMI Post 6R Refueling

Outage Startup Review List," the operations department list of jobs

to be completed, the training handout for HSPS, portions of plant

operating procedures affected by changes to the HSPS, and proposed

HSPS technical specification changes as submitted by the licensee on

January 28, 1987.

The inspector performed walkdowns of principal portions of the EFW,

HSPS, and the two-hour backup air supply systems.

2.2 Findings / Conclusions

2.2.1

General Findings

The Plant Operations Director (P00) assigned an engineer

with shift technical advisor qualifications and experience

to act as a single point of contact for HSPS for the de-

partment. That individual was to become familiar with the

system, provide training and training material to the de-

partment, provide input to designers on operational needs,

and to prepare necessary procedure changes for HSPS.

The

inspector found the engineer to be very knowledgeable,

thorough, and effective in carrying out his assigned tasks.

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The licensee has decided to administer the annual operator

requalification examinations just prior to startup. Ques-

tions will reflect plant modifications incorporated during

the outage. This appears to be an effective way of assur-

ing operator . familiarity with these modifications and a

good way to refresh operator knowledge prior to return to

power operations.

Operations department detail review of, and input to, the

design of the HSPS system did not occur until near the

beginning of the refueling outage.

As a consequence, it

was barely possible to incorporate significant HSPS design

changes requested by the operations department.

2.2.2

Tracking System

The inspector reviewed the licensee's " Post 6R Refueling

Outage Startup Review List." This is a compilation of all

prerequisite activities that must be accomplished prior to

startup. Each division provided input to the document and

approved its scope and content.

This listing was being

actively used by company managers to track progress and was

being regularly updated.

Its general level of detail went

to the point of including such items as individual system

valve alignments to be performed.

At the time of the

inspection, many activities were still indicated as out-

standing in the operations area (e.g., all valve alignments

had yet to be

performed and 56 procedures required

revision).

In support of the startup review list, the operations de-

partment was using a more detailed tracking list.

The

operations' list was also being closely monitored and regu-

larly updated.

To check the validity of the operations

tracking system, the inspector verified that the procedure

changes initiated by the operations coordinator for the

HSPS modification were included on the operations' list and

that several of those changes that were noted as completed

(distributed) had indeed been incorporated into plant

procedures.

The above tracking methodology was successfully used by* the

licensee for the TMI restart in 1985 and for the eddy cur-

rent outage in 1986. This, coupled with the fact that the

.

system is being emphasized and closely monitored by senior

licensee managers,

provides confidence

that

necessary

activities will be accomplished prior to restart.

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The inspector discussed the large number of outstanding

items with the Plant Operations Director (P00) and ques-

tioned whether all necessary items could physically be

accomplished by the tentatively planned startup date of

March 20, 1987. The POD indicated that a delay in startup

may be considered to allow additional time to perform

checkouts and tests of modified systems.

2.2.3

Labeling of HSPS Cabinets

The HSPS control circuitry is housed in four cabinets. Two

of these cabinets contain only a single instrumentation

channel.

The remaining two cabinets each house both

instrumentation for a single channel and for an actuation

train.

Train actuations' can be initiated if cabinet test

~

switches are improperly positioned. This could cause inad-

vertent isolation of main feedwater to the steam generator

(OTSG) and emergency feedwater actuation for example. By-

pass switches which are similar in appearance are located

in the channel instrumentation sections.

At the time of the inspection, the cabinets only had labels

indicating the instrument rack numbers. An individual not

familiar with rack numbers could possibly enter the wrong

cabinet. In fact, an engineer supervising the HSPS modifi-

cation opened the wrong cabinet door when he was showing

the inspector connector points within a cabinet.

Control

room operators only have a general annunciator to indicate

that a HSPS cabinet door has been opened. They do not have

indication that a channel has been placed in test.

The

backs of the channel and train cabinets are similar in

appearance and have similar labeling of terminal boards.

Because of the potential for initiation of unwarranted HSPS

trips due to operator / technician error, the inspector ex-

pressed concern that the labeling may need improvement.

The inspector was told that similar concerns have been ex-

pressed by members of the plant staff. Licensee management

agreed that the adequacy of HSPS cabinet labeling would be

reviewed subsequent to completion of testing and initial

checkout of the system, which may occur after startup. The

area of human factors labeling of the HSPS cabinets is

unresolved pending completion of licensee committed action

and subsequent NRC:RI review (289/87-06-01).

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2.2.4

Operator Training and Interface with Engineering on HSPS

The inspector reviewed an operator training handout on

HSF3. The handout was written by the operations coordina-

tor for the HSPS modification. That individual was aware

that the System Design Description (SDD) TI-4248, Division

II, was not up to date and he worked with the system

designers to ensure that the training handout was correct.

All operating crews received four hours of classroom train-

ing on HSPS. All will also receive a plant walkthrough of

the system. At the time of inspection, not all crews had

received the walkthrough training.

During development of the training material and during the

training administration, the operations coordinator and

operations personnel noted weaknesses in system design.

They noted that following HSPS actuation on low steam

generator pressure, the feedwater isolation signal cannot

be defeated if OTSG pressure returns above the actuation

setpoint of 750 psig.

They noted that there was no capa-

bility to select an alternate indication of OTSG level in

the event of failure of the level transmitter locally

selected to feed the ICS system.

These weaknesses were

pointed out to system designers and improvements were

implemented (feedwater isolation defeat capability im-

proved, a median selector switch added, and a non-safety-

related backup power supply added for train power).

2.2.5

Procedure and Drawing Changes

The inspector reviewed with the operations coordinator for

HSPS the changes that have either been made or have been

initiated to operating procedures as a result of the HSPS

modification and the associated technical specification

changes. The coordinator appeared to have done a thorough

job in determining which procedures required revision and

in initiating required changes.

Changes still outstanding

were being tracked in the operations department tracking

system.

The inspector noted that no guidance was provided to opera-

tors on the possible need for defeating the main feedwater

(MFW) isolation function if MFW is used to increase OTSG

level to the 90-95 percent control range in the event of a

small break loss of coolant accident (SBLOCA).

Isolation

occurs at 94 percent level und would impede the ability to

use MFW in this situation.

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The licensee stated that emergency feedwater (EFW) is the

most effective means for raising OTSG level during a SBLOCA

and that their procedures adequately addressed EFW.

They

feared that including instructions on MFW use would un-

necessarily complicate their emergency procedures which

could hamper operator efforts.

Further, an alarm response

procedure cautions the impending MFW isolation on high OTSG

level.

While the inspector agreed that the general philosophy of

simplifying procedures was sound, he noted that, due to the

importance of the OTSG cooling path in a SBLOCA in a B&W

designed plant, consideration of the use of MFW as an al-

tornate means of providing water to the OTSG may be appro-

priate. Therefore, the P00 agreed to further evaluate the

need for addressing MFW isolation specifically in the

emergency procedures. The need for this procedure revision

is unresolved pending completion of licensee review and

subsequent NRC:RI review (289/87-06-02).

The inspector performed partial walkdowns of the EFW and

the two-hour backup air supply systems.

He noted that the

controlled drawings for these systems have not been updated

to reflect outage modifications.

The inspector understood

that these drawings would be updated prior to startup as

part of the modification completion process (see also

Section 5).

2.2.6

Potential Design Weaknesses

During a walkdown of the two-hour backup air supply system,

the

inspector noted

that both

seismically qualified,

safety-related two-hour supply headers provide motive air

to the diaphragm control valve (MS-V-6), which regulates

steam pressure to the steam-driven emergency feedwater

pump.

The inspector questioned the effects of a diaphragm

rupture during EFW system operation to verify that this

single failure could not bleed down the redundant air

headers and render them inoperable.

A design requirement

for the air system is that it remain operable in the event

of a single failure.

The inspector was concerned that in

the high temperature environment in which the valve is

located the rubber diaphragm could degrade (as has occurred

at another nuclear power plant) and rupture.

The MS-V-6

fails open on loss of air pressure.

This would increase

steam pressure to the pump and the controller would pro-

bably port additional air to the valve in an attempt to

close it to reduce line pressure.

Such action could bleed

the air headers down.

The licensee's single

failure

analysis should address this concern (289/86-12-02) (see

Section 5.3).

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2.2.7

HSPS Interface with the Integrated Control System

,

The inspector discussed with the operations HSPS coordina-

tor the possible effects of HSPS system failures on the

Integrated Control System - (ICS)

With the inclusion of

.

the median power supply in system design, it appears that

failures would be benign and the more plausible failures

l

would be indicated to the operators (see also Section 5).

'

2.2.8

Control of Spare Connections from HSPS to the Reactor

Protection System

At one time, the licensee intended to have interconnections

between the HSPS and the Reactor Protection System (RPS).

The inspector was told by licensee personnel that this

connection will not be made.

The inspector examined the

connection terminals that would have been used and con-

firmed that no connections existed and no spare output

leads existed which could, if not properly terminated,

ground against each other or the cabinet itself.

2.3 Summary

Licensee tracking systems appeared to adequately identify and track

work activities to be completed prior to startup.

Many items were

still outstanding.

However, these systems were being actively used

and monitored by station managers, thus providing assurance that

outstanding items will be completed.

The use of a single coordinator for the operations department for the

HSPS modification appeared to have provided an excellent means for

assuring that feedback to designers was provided and that necessary

procedure changes and training were accomplished or initiated. Oper-

ations detailed interface with HSPS designers was not initiated until

the start of the refueling outage; however, no deficiencies were

noted by the team which were attributable to this relatively late

interface.

Labeling of the HSPS cabinets appears confusing and may result in the

possibility of spurious trips due to operator / technician error. A

possible design weakness noted by the team in the two-hour backup air

supply system will be evaluated by the licensee and NRC staff. The

HSPS interface with ICS does not appear to create the possibility of

adverse effects on ICS or HSPS.

Licensee consideration is being given to possible inclusion into the

procedures of the use of main feedwater in providing water to OTSG's

during SBLOCA conditions and an appropriate caution statement ad-

dressing MFW isolation (unless defeated) when approaching the 95 per-

cent level on the OTSG operating range.

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3.

Maintenance

3.1 Criteria and Scope of Review

Plant maintenance programs were reviewed to verify that the licensee

had developed, implemented, and maintained a corrective and preven-

tive maintenance program necessary to ensure the operability of

safety-related systems. Of importance during this inspection was the

review of maintenance activities accomplished during the present 6R

4

outage and an assessment of those activities that would be deferred

,

until after startup or during the 7R outage.

In addition to a program review, NRC team members witnessed on going

maintenance activities and discussed maintenance-related activities

and administrative controls with ' appropriate personnel .

They also

assessed present staffing levels and management involvement within

this area.

Interviews were held with maintenance department nerson-

nel (mechanical, electrical, and instrument and controls) and inter-

facing departments, including operations, engineering, and quality

assurance. Acceptance criteria for this review included ANSI N-18.7-

1976Property "ANSI code" (as page type) with input value "ANSI N-18.7-</br></br>1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. and the licensee's (NRC approved) Quality Assurance Plan (QAP).

Discussions were held with the planning and scheduling manager to

determine the manner in which maintenance activities, both preventive

and corrective, were planned, scheduled, tracked, and documented.

Discussions were also held with the preventive and corrective main-

tenance managers to assess their involvement with the accomplishment

of maintenance activities.

Administrative procedures utilized to control the conduct of work,

along with completed work packages, were revie,ved to verify the

following:

required administrative approvals were obtained prior to com-

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mencement of work;

approved procedures and/or instructions and controlled drawings

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were used during the accomplishment of work;

appropriate post-maintenance testing was completed prior to

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declaring a system or equipment operable;

QC notification points, where deemed applicable, were appro-

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priately placed within the procecure;

qualified test equipment and tools were identified;

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procedures and appropriate data sheets were properly completed;

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acceptance criteria were met;

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appropriate reviews were completed as required; and,

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records were assembled, stored, and retrieved as part of ' main-

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tenance history.

Direct observation of on going maintenance activities was also per-

I

formed during the inspection to provide verification of the comple -

'

tion of the above attributes. This observance of work also gave the

inspector the opportunity to assess actual work practices and com-

munication and coordination between various work groups.

The inspector also assessed present staffing levels and reviewed

management's . involvement in the maintenance area.

This review,

coupled with a review of outstanding job orders, provided the team

l

with an indication of the adequacy of staffing levels and management

'

involvement.

3.2 Findings / Conclusions

,

3.2.1

General

This review indicated, overall, that the conduct of maintenance

activities is performed by an organization dedicated towards

maintaining plant equipment in a state of operational readiness.

No obvious weaknesses were determined during this review. Coor-

dination of efforts between various on-site disciplines was

evident and the prioritization of outstanding work activities

I

was viewed as an excellent assessment of what had to be accom-

1

plished prior to restart.

3.2.2

Preventive / Corrective Maintenance

,

)

The inspector found preventive maintenance (FM) and corrective

maintenance (CM) programs to be well maintained, controlled, and

l

documented.

Various weekly status sheets summarize the status

of outstanding job orders to which PM and CM work activities are

written against. These status reports also provide the amount

of progress being made in various areas, thus, enabling manage-

ment to effectively analyze areas where a backlog of scheduled

maintenance might effect the operability of safety-related

,

equipment.

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Various computerized and manual mechanisms were found to be in

place that documented and tracked the status of work activities.

Utilizing

these mechanisms,

supervisory personnel

recently

prioritized all existing job orders to determine which tasks

needed to be completed prior to restart compared to those which

could be deferred.

Many deferred tasks will be accomplished

during planned system outages that presently are scheduled after

restart.

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The PM data base is quite extensive as noted by the inspector's

review.

Much effort has been expended towards evaluating and

expanding upon the preventive maintenance program.

Increased

emphasis was placed in this area in 1979 and has continued

since.

The inspector questioned the licensee as to whether any

PM requirements are in place for manually operated valves,

particularly EF-V-52, 53, 54, and 55.

Another reactor of the

B&W design experienced

difficulty

in

operating

similarly

designed, manually operated isolation valves. At TMI-1, the EFW

,

discharge isolation valves (EF-V-52, 53, 54, and 55) are man-

ually operated block valves down stream of four parallel flow

control valves that fail closed on a loss of air. As depicted

in NRR's

Safety Evaluation

relating to NUREG 0737,

Item

II.E.1.2, Emergency Feedwater system, NRC staff approved the

design change to make the EFW flow control valve fail closed and

,

the discharge isolation valve to be manually operated.

These

valves could require local manual operation (closure) in the

event of a main steam line break inside containment with an EFW

flow control valve failure.

Licensee representatives stated

that PM requirements have yet to be identified for the above-

(

mentioned valves. Until particular PM requirements are assigned

to EF-V-52, 53, 54, and 55, this area will remain unresolved

'

(289/87-06-03).

Significant work has been accomplished within the areas of

'

MOVATS testing of motor operated valves and valve packing re-

pairs during the present outage.

All motor-operated valves

,.

'

within the scope of NRC:IE Bulletin 85-03 have been tested along

with numerous others. Again, priority lists have been generated

detailing the order in which valves are to be tested.

Addi-

!

tional review on the part of the licensee has indicated that

many of the valves are overrated; thus, many valves, including

those previously tested, will have their torque switches read-

justed to produce more conservative thrust values.

A group was dedicated solely to repacking valves during this

outage.

Efforts are continuing in this area. Again, priorit-

ized lists were generated to facilitate the accomplishment of

this endeavor.

The inspector noted that over 350 valves had

been repacked during this outage.

-

. _ - _ _ _

.

.

12

3.2.3

Maintenance Activities

The inspector observed the work in progress on valve

MS-V-009A.

This swing check valve had been disassembled

for inspection purposes and workers were presently perform-

ing resurfacing work on the valve seat prior to running a

dye check.

Initial disassembly of MS-V-009A had revealed

that the disc stud nut, washer, and cotter key were miss-

ing. The valve was found to still be operable.

Further

investigation, as dispositioned by engineering, resulted in

locating the nut and washer; however, the cotter key was

never found.

Upon visual

inspection of the disassembled valve, the

inspector questioned the looseness of the valve disc nut-

to-stud fit. Further review indicated that engineering had

previously identified and evaluated the same concern. Final

resolution was to secure the nut-to-the-disc stud by lock

welding in addition to installing the cotter pin.

This

will make any future valve disassembly more difficult; how-

ever, it does provide additional assurance of the integrity

of the valve.

Similar actions were performed on MS-V-009B

even though no problems had been identified.

The inspector also observed the conduct of PM Procedure

E-5, 480 V Circuit Breaker - Inspection and Testing, which

dealt with solid state trip devices.

The inspector found

the appropriate attributes, as detailed in paragraph 3.1,

to have been effectively accomplished.

3.3 Summary

The team found that the various divisions of the maintenance depart-

ment were adequately staffed. Maintenance supervisory personnel were

knowledgeable of on going activities and have effectively maintained

control of scheduled activities throughout this outage. Communica-

tion and coordination between maintenance and other groups appeared

to be more than adequate. Organization and quality of completed work

packages were excellent.

4.

Surveillance

4.1 Criteria and Scope of Review

The licensee's established program for the scheduling and control of

surveillance te: ting activities was reviewed.

Review criteria con-

sisted primarily of the technical specification requirements and the

requirements of Station Procedure 1001J, Technical Specification

Surveillance Testing Program. The adequacy of the station procedure

has been previously reviewed during the inspections associated with

the plant startup.

'*

.

..

13

Specific areas inspected were:

control, scheduling, trackir.g, and evaluation of surveillance

--

tests;

verification of the completion of all technical specification

--

required refueling interval procedures;

control of exceptions and deficiencies (E&D's) associated with

--

completed surveillance test procedures;

1

verification that procedures have been prepared for the surveil-

l

--

lances required by recently issued Technical Specification

Amendments;

I

detailed review of the past performance of one set of instru-

--

ments which will be associated with the HSPS installation;

--

the QA monitoring and inspection of the surveillance testing

program; and,

previously

identified unresolved

items were evaluated for

--

possible impact on startup.

4.2 Findings / Conclusions

4.2.1

Surveillance procedure Controls

,

l

The licensee controls the surveillance test program by

Station Procedure 1001J, Technical Specification Surveil-

lance Testing Program.

This procedure specifies the re-

!

I

sponsibilities of various individuals associated with the

surveillance test program, specifies the general flow pro-

cess for the performance of a surveillance test, and the

requirements associated with the accomplishment of a test.

The procedure provides for the disposition of problems

encountered during surveMlance testing by defining excep-

tions and deficiencies and specifying the method of resolv-

ing of these exceptions and deficiencies.

Surveillance

test review and record keeping requirements are also

specified by the procedure.

The licensee's adherence to requirements of the procedure

was reviewed in detail with particular emphasis on the

scheduling of required testing.

Specifically, the schedu-

ling of refueling interval surveillances was inspected,

since these are the most difficult to schedule by use of a

computer.

_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

. _ _ _ _ _ .

.

.

14

A review of documentation, the computer generated surveil-

lance checklist, and discussions with facility personnel

indicates that the general requirements of Procedure 1001J

are being fulfilled.

In the area of tracking and schedu-

ling of refueling interval surveillances, significantly

more controls have been established than are procedurally

required.

The 1001J preventive maintenance supervisor is aware of

certain improvements which can be made to the procedure to

more specifically reflect the controls which have been

established.

These procedure changes are expected to be

incorporated into the procedure by August 1987.

The con-

scientious efforts on the part of personnel involved in the

tracking, scheduling, and assuring completion of required

testing is noteworthy. As an additional check to the con-

trols established to assure completion of required surveil-

lance testing, the Operating Procedure 1102-1, Plant Heatup

to 525 F, specifies additional verification that technical

specification-required surveillances have been completed.

With the controls which have been established, performance

of required testing within the interval specified appears

to be assured.

4.2.2

Refueling Interval Surve111ances

Records verifying the completion of all surveillance tests

required to be performed at a refueling interval were

reviewed to determine that each has been performed as

j

required.

In addition to computer generated data indicating late

completion dates for scheduled tests, a manual list is

!

maintained which identifies tests to be performed prior to

l

the completion of this outage.

An additional control, a

,

l

regulatory retest log, has been established for tests

which, due to plant conditions or equipment out of service,

cannot be performed when scheduled.

The maintenance of

'

this log by control room personnel was verified.

At the time of the inspection, there were no overdue re-

fueling interval-required tests.

Some tests which would

come due during the operating cycle are scheduled to be

performed during the outage and tests which had been

scheduled, but could not be perfonned, are being tracked.

_ _ _ _ _

~

'

.

.

15

4.2.3

Completed Procedure Review

The inspectors reviewed selected completed surveillance

tests to verify that test procedures were properly com-

pleted, test results were reviewed as required, data and

test results were acceptable, and that corrective action

was taken where necessary.

Completed surveillance tests

reviewed during this inspection are listed in Attachment 2.

During the review of Procedure 1302-5.10, Reactor Building

4 psig Channel, performed February 11, 1987, the inspector

found a wire / jumper control sheet attached, which identi-

fied the lifting of certain leads during the performance of

the surveillance test.

The jumper control

sheet also

verified the proper reconnection of the lifted leads. The

jumper control sheet is part of a licensee procedure which

controls lifted leads and jumpers.

A review of the surveillance procedure as written did not

identify any leads which required lifting. Subsequent dis-

cussions with licensee personnel disclosed that the proced-

ure was not performed as written; that is, the calibration

of the entire loop at one time.

Rather, the calibration

was performed component by component.

Further discussions

with licensee personnel indicated that a number of loop

calioration procedures had been changed to permit and pro-

vide instructions for component-by-component calibration;

consequently, technicians were accustomed to performing

calibrations in this manner.

This procedure, however, had

not been changed and the failure to initiate a procedure

change prior to the performance of the procedure is con-

sidered to be an apparent violation of TS 6.8.1 (289/

87-06-04).

It was noted that, in the performance of the test, measures

were established to control the necessary lifting and

reconnecting of leads.

4.2.4

Control of Problems Encountered During Surveillance Testing

The licensee has established a means of documenting and

evaluating problems encountered during surveillance test-

ing.

This control is achieved through the use of a "TS

.

Surveillance Exception and Deficiency (E&D) Sheet." Defic-

iencies are equipment problems or malfunctions or a test

not completed. These must be immediately identified to the

shift

supervisor.

Excaptions

are

non-substantiative

changes which do not alter the intent or scope of the pro-

cedure.

Exceptions must also be identified to the shift

supervisor prior to implementation.

_

__.

_ _ _ - _ _ - _ -

.

16

Both exceptions and deficiencies are documented as is the

resolution of exceptions and deficiencies. A log of open

deficiencies is maintained in the control room. Also, the

preventi.ve maintenance supervisor maintains a log of open

deficiencies.

Licensee representatives stated both logs

and all completed surveillance procedures will be reviewed

for unresolved items prior to startup from this outage.

In

addition, the plant heatup procedure requires the review of

unresolved surveillance discrepancies.

The licensee's controls to ensure exceptions and deficien-

cies are resolved prior to plant startup appear to be

adequate.

4.2.5

Surveillance Procedures Required by Technical Specifications

Amendments

A review was conducted to verify that the required surveil-

lance test procedurcs have been prepared for several re-

cently issued Technical Specification amendments.

The

preparation of selected procedures for surveillances spec-

ified in Amendment Nos. 119, 122, and 123 were verified.

The procedures were reviewed to determine that prerequi-

sites were specified, the procedure was technically ade-

quate to ensure that testing ensures compliance with re-

quirements, acceptance criteria were specified, required

data are recorded, and proper procedure sign-off and review

are specified.

For all surveillance requirements selected adequate proced-

ures have been prepared.

Several of the procedures were

noted to have been just recently issued. The surveillance

requirements and associated procedures, which were re-

viewed, are listed in Attachment 2.

For the HSPS currently being installed, only one quarterly

proposed technical specification required surveillance pro-

cedure is currently under review.

The licensee intends to

perform this one surveillance prior to startup to avoid the

risk associated with the first-time performance of a pro-

cedure with the plant in operation. The surveillance test-

ing requirements for a first surveillance test of a newly-

installed system are intended to be completed using startup

and test data. To ensure compliance with technical spec-

ification surveillance requirements, the Plant Review Group

(PRG) will review completed startup and test packages to

verify technical specification compliance.

This review

will be performed and documented before plant startup.

_ - _ - .

6

• .

.

17

4.2.6

Review of Delta Pressure Instrument Performance

One of the existing surveillance requirements for the start

of EFW pumps is the loss of both feedwater pumps indica-

tion, which provides input to the emergency feedwater auto

initiation instrument channel. The loss of feedwater pumps

is detected by four delta pressure switches which sense

feed pump suction and discharge pressures.

Two switches

are associated with each channel.

These switches were previously installed and operating as

part of the existing protection system. A review was con-

ducted of the past performance of those devices.

These

devices were selected for review to verify the adequacy of

a refueling interval calibration frequency (18 months plus

or minus 25 percent), since the quarterly required surveil-

lance does not verify the instrument setpoint and, also,

because the failure of any single instrument will also

cause the failure of one channel to initiate. No failure

of a single instrument will

cause both channels

to

initiate.

The feedwater pump delta pressure is sensed by four instru-

ments identified as FW-DRS-829, 830, 542, and 543.

Data

associated with previous testing was reviewed. Results of

this review are as follows:

12/18/81

Test

829

All failed to meet test

830

acceptance criterit.

542

543

&

6/21/83

'

Test

543

Failed to meet test

acceptance criteria

7/23/84

Test

829

Failed to meet test

acceptance criteria

2/1/86

Test

829

All failed to meet test

830

acceptance criteria

852

543

Since the plant experienced little operating time from 1981

to 1985, the most recent test data are the most meaningful.

The instrument activation setpoint is specified as 50 psig.

The "as-found" data for the 1986 test was as follows:

-

-

-

-

-

1

%

e

1

18

l

DPS 542 "As-Found" Setpoint - 22 psig

DPS 543 "As-Found" Setpoint - 14 psig

DPS 829 "As-Found" Setpoint - 55 psig

DPS 830 "As-Found" Setpoint - 67 psig

As a result of finding all four switches out of calibra-

tion, a plant engineering evaluation request was prepared

on February 3, 1986.

A response to this evaluation was

approved on November 17, 1986, which included a recommenda-

tion and a suggestion that the devices be checked during

this outage.

Prior to this inspection, these instruments

were not scheduled for calibration during this outage.

The performance of these instruments was discussed with

licensee personnel. During these discussions, the licensee

stated that: (1) the instruments would be calibrated prior

to startup (this had been performed and data were under

~

review at the conclusion of the inspection); (2) based on

the review of instrument performance, the adequacy of a

refueling interval calibration frequency would be deter-

mined; and, (3) since the instrument now provides input to

a different channel logic, the setpoint and acceptance

criteria would be evaluated.

This will be accomplished prior to plant startup. The com-

pletion of the licensee's actions is considered to be an

unresolved item (289/87-06-05).

4.2.7

QA Monitoring of Surveillance Test Program

The surveillance test program procedures states:

"The

manager, TMI QA Mod / Ops, is responsible for providing mon-

itoring and inspection of the surveillance test program

..." This monitoring of the surveillance test program is

accomplished primarily by the frequent monitoring of sur-

veillance activities.

Records show that many surveillance

activities have been monitored. Also, detailad tronitoring

of the Fuel Handling Building (FHB) Engineered Safeguard

Features

(ESF)

Ventilation

System

modification

was

performed.

'

Among the findings resulting from these monitorings are

that in the preparation of some test exceptions certain

procedure change requirements may be bypassed. A change to

.

Administrative Procedure (A)) 1001J was made to more spec-

ifically describe what constitutes a test exception. This

area will probably require continued licensee attention.

..

.

19

.

Also, in the conduct of performing initial surveillance

testing for the FHB ESF ventilation modification test pro-

cedures, which were classified as not important to safety,

were implemented to verify technical specification surveil-

lance test requirements, which are classified as important

to safety.

The resolution to this finding was a commitment that until

such time as 1001J is revised to define the process of

initial technical specification surveillance testing of

plant modifications, the Plant Review Group will review

completed startup and test group test packages as appli-

cable to verify technical specification compliance.

The QA monitoring of the~ surveillance test program is being

performed as specified by 1001J.

4.2.8

Previously NRC Identified Outstanding Items

Certain previously identified items judged to pertain to

the area of surveillance were evaluated for possible impact

on plant startup following this outage.

The items evalu-

ated were Unresolved Item Nos. 289/86-19-03, 86-17-03,

86-12-02, and 86-12-09. Nothing was identified which must

be resolved prior to plant startup.

4.3 Summary

The licensee has established a detailed procedure which describes the

conduct of the surveillance testing program.

Within the scope of

this review, the program appears to be conducted in accordance with

procedural requirements.

Significantly more is actually being per-

formed in the scheduling and tracking of surveillance testing than is

required by the procedure. The personnel involved in the assurance

that all surveillances are being performed as required were noted to

be extremely knowledgeable of the surveillance program status and

extremely conscientious in carrying out their responsibilities.

No overdue surveillances were identified; surveillance procedures

were noted as being adequate and for the most part are being adhered

I

to.

Problems identified during the performance of testing are docu-

mented, tracked, and resolved in accordance with procedural require-

ments. QA monitoring or surveillance activities is being performed

with some substantive problems being identified.

.

The violation and unresolved items which were identified, as well as

the QA findings, do not indicate a lack of controls but rather the

need for the continuation of personnel training on all levels, tech-

nician as well as supervisory, to be continuously vigilant for condi-

tions adverse to quality.

l

!.

. . -

,

.

- . . .

_ . - -

. . - -

.

.>

.

20

a

5.

Technical Support (Modification and Test Control)

5.1 Modification Control

5.1.1

Criteria and Scope of Review

1

The inspectors reviewed the instrumentation and controls

portion of the Heat Sink Protection System (HSPS) design

modification.

The criteria used to evaluate the operabil-

ity and design requirements were the System Design Descrip-

tion (SDD), Division I and II. The SDD design requirements

were further evaluated against committed standards, includ-

ing applicable IEEE Standard (e.g., 279-1971 and 388-1981);

NUREG 0737; the TMI Final Safety Analysis Report (FSAR);

and, commitments made as'a result of correspondence submit-

ted with respect to NUREG 0737, II.E.1.1 and 2.

Particular

emphasis was placed on evaluation on how the HSPS design

meets the five criteria of single fail ure , independence,

availability, loss of power, and redundancy.

While at GPUN Corporate headquarters in Parsippany, New

Jersey, the inspector interviewed key project personnel

during the conduct of the inspection.

The SDD for . the

emergency feedwater system upgrade to safety grade design

was reviewed to establish the design criteria / input and to

evaluate the system limitations and setpoints.

The design

calculations for the HSPS system were also reviewed.

The inspectors reviewed HSPS design drawings to ensure that

design input data were accurately reflected in the system

design documents.

A list of documents reviewed is con-

'

tained in Attachment 2.

In addition, during the week of February 23, 1987, at the

TMI plant site, the inspectors performed a wal kdown of

equipment associated with the HSPS.

The in plant review

included a walkdown of the modifications done in the con-

trol room and the relay room.

The inspectors visually

observed the new HSPS cabinet and the new cable and conduit

runs installed to support the modification.

5.1.2

Findings / Conclusions

5.1.2.1

Essential Design Elements of Restart License Condition 3(a)

.

The inspectors reviewed the applicable documents that ad-

dressed the licensee's action on the required Restart

License Condition 3(a) modifications. A significant amount

of the design change and plant modification was incorpor-

ated into one large plant modification, HSPS.

The HSPS

,

~u

- - - - - .

e . . , , - - , ,

,. . - , -

,

--

,,,y-

.-,,

,,,---,,w

, . , . - , -

-

_

g

.,

21

modification installed 0TSG high and low level alarms, up-

graded the main steam line rupture detection system and the

necessary logic circuits and control to make EFW safety

grade from an electrical perspective.

A detailed review of the HSPS determined that the licensee

had incorporated into the plant the required control and

automatic initiation systems.

In general, the design followed applicable IEEE standards.

Discussions with responsible cognizant design engineers

indicated the personnel involved were knowledgeable of the

design basis and purpose of the modification.

The design

change, which

was a major modification and significant

work and engineering effort, had been performed in a manner

to ensure the final design had minimal effect on how the

plant responded and, subsequently, operated.

Sound engi-

neering judgement was used in the original concept of the

modification and subsequent upgrades which were required as

part of Appendix R or field modification. Within the scope

of this review, the inspectors did note several concerns

that are described in the following sections. The concerns

mainly dealt with proper documentation of the work and sub-

sequent revisions and not the actual engineering or the

engineering philosophies that was applied to the design.

The inspectors concluded that work was in progress to com-

plete all of the plant modifications as proposed by the

licensee to meet the intent of TAP Item II.E.1.1 and

II.E.1.2 of NUREG 0737.

All modifications were scheduled

to be completed and tested prior to restart of the unit

from 6R outage.

5.1.2.2

Incomplete Licensee Analyses

The inspectors asked to review the Failure Modes and

Effects Analyses (FMEA) for HSPS but were informed that the

FMEA that had been performed had been determined by the

licensee to be inadequate and a new FMEA was being per-

formed.

The licensee has committed to complete the FMEA

and incorporate any required changes prior to startup

(289/87-06-09).

The inspectors also requested to review

the High Energy Line Break (HELB) analyses on the HSPS but

were informed that this study had been performed but had

not been documented as yet.

The licensee has committed to

complete and document this analysis and incorporate any

required modifications prior to startup (289/87-06-08).

In

addition, the team noted that the licensee was still in the

process of seismically qualifying the air controller for

MS-V-6.

The licensee stated that this review would be

completed prior to startup (289/87-06-08).

.

.

22

5.1.2.3

Voltage Drop Calculation

The inspectors, while at the site, interviewed organiza-

tions involved in the design of HSPS. During these inter-

views, it was determined that no voltage drop calculations

have been performed on circuits involved with HSPS. In the

case of voltage drop analysis, it is critical to the design

of power and control circuits that applied voltage be with-

in the minimum voltage requirements of safety-related

equipment. The licensee has committed to perform the cal-

culations necessary to assure that minimum voltage require-

ments are met prior to startup. Further, the short circuit'

study and breaker coordination study, as required by 10 CFR 50 Appendix R, has not been completed.

In the case of fault and breaker coordination studies, the

licensee has committed to perform a coordination study of

safety-related

a.c.

and

d.c.

protective devices (289/

87-06-09).

5.1.2.4

Design Input / Output Control

A review of the calculation associated with low OTSG level

EFW actuation setpoint determined that a revision to the

calculation had been performed. The revision had not been

performed per applicable corporate procedures and a summary

sheet of calculation revision had not been prepared as

required by Technical Procedure EP-006, Revision 2-01,

Design Calculations.

Because the applicable procedure was

not followed, the design calculation did not receive the

same level of review as the original calculation.

Specif-

ically, this change was not reviewed and validated as

required by EP-006. The data were then transmitted to the

site via FCR and the instruments calibrated to these set-

points.

Failure to properly review and verify the design calcula-

tion associated with OTSG low level EFW actuation setpoint

is considered an apparent violation of the 10 CFR 50

Appendix

B,

Section III and the licensee's Operational

Quality Assurance Plan, Section 4.2.12 (289/87-06-06). The

inspectors reviewed the setpoint calculation revision and

determined that, even though the change was not adminis-

tered properly, it did improve the overall calculation.

.

-_

_ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _

_ _ _ - _ . __

.

'

?.

.

i

23

One setpoint (EFW pump start setpoint at 15 inches) con-

tained no tolerance and had no basis in the loop error

calculation. The setpoint tolerances assigned to the other

setpoints transmitted in the FCR were not considered in the

loop error calculation. Additionally, instrument inaccura-

cies due to accident conditions were not accounted for in

the loop error calculations. Finally, the assumptions made

in the calculations have not been verifiea; in particular,

vendor-supplied tolerances wera not verified to be the

proper values.

The licensee, who was in the process of

re-doing the calculation, has committed to review the

inspector's concerns prior to startup to ensure that the

correct setpoints for the HSPS are established.

5.1.2.5

Configuration Control

The team reviewed several Field Change Requests and Safety

Evaluations (SE) to evaluate both the change process and

the technical adequacy of the resolutions.

The field

change process adequately handles field questions which

require engineering resolution. With respect to changes to

SE, the licensee's system presently allows revisions to

pages by whiting out the revision number on a page and then

typing the new revision number over the old number. This

occurred for Revision 1 to SE No. 412024-004. Revision 0,

however, was retrievable from document control in its

entirety.

In addition, required review signatures asso-

ciated with changes do not identify which signatures are

satisfying which reviews.

The inspector noted that this

process made it very difficult to ensure the changes were

administered correctly.

For the revision reviewed by NRC,

it could be inferred from the signatures present that the

proper reviewers had, in fact, been involved.

In addition, a review of the areas changed by Revision 1

indicated that certain areas / elements for consideration;

i.e,

seismic consideration, were not revised.

The bases

for not revising these sections were not clearly documen-

ted.

If an area was affected, additional narrative was

added to justify the new conclusion that the change did not

have an adverse effect on safety.

If an element was not

affected, no additional narrative was added.

Independent

review by the inspector of the elements where no new narra-

tive was added indicated that these areas were not essen-

tially affected by the change.

It did, however, make the

review of the revision impossible to veri fy , short of

interviewing

each

reviewer,

whether

the

individual

reviewers considered all elements or areas as part of their

review.

_

_

_ _ _ _ _ _ _ _

'

,.

.

24

The inspector found that the SDD's contained incorrect

(outdated) information and did not always reflect the

latest design data.

The licensee has committed to amend

the SDD's Division II by posting Field Change Requests

(FCR's) prior to startup against SDD's and then to revise

the SDD's to reflect "as-built" system configurations after

startup.

Some random reference errors and incorrect setpoints were

found on the HSPS drawings.

One significant error of

omission was found in that the startup range channel bypass

switches were not incorporated on the Foxboro functional

drawings. The inspector was concerned that because of the

errors found, and because the GPU logic diagrams for the

HSPS are not being updated, the control room would not have

drawings reflecting the "as-built" conditions at the time

of startup. The licensee has committed (in a previous NRC

<

inspection) to mark up the control room drawings prior to

startup and to revise the drawings within thirty days

(289/86-14-03).

5.1.2.6

Plant Walkdown

During the in plant walkdown, it was noted that in Section

T5 of HSPS Cabinet Al did not have a minimum separation of

6 inches between IE and non-1E wiring. Minimum separation

distance must be maintained or analysis / testing performed

to show that separation of less than 6 inches is acceptable

as required by IEEE Standards. The licensee plans to ad-

dress this before startup (289/87-06-09). Additionally, it

was determined that a seismic Category 2 over seismic

Category 1 interaction walkdown was not performed.

The

licensee has committed to perform a walkdown to verify no

adverse interaction between seismic Category 2 and seismic

Category 1 equipment as required by Regulatory Guide (RG) 1.29(289/87-06-08).

5.2 Preoperational Testing

5.2.1

Heat Sink Protection System (HSPS) Test Procedure Review

5.2.1.1

Criteria and Scope of Review

During the recent refueling outage (Cycle 6), the licensee

.

installed the HSPS to conform to NUREG 0737, Item II.E.1.2,

Auxiliary Feedwater System. The HSPS provides for several

functions such as automatic initiation of emergency feed-

water (EFW) on Once-Through Steam Generator (OTSG) low

water level, high containment pressure, loss of feedwater

pumps and loss of reactor coolant pumps. The system also

isolates main feedwater to the OTSG on high water level and

low OTSG pressure.

m .

.

'

,

.

25

The preoperational test procedures listed below were re-

viewed for technical and administrative adequacy and to

verify that testing planned or conducted would adequately

satisfy . regulatory guidance and licensee commitments. Spec-

ific observations included proper licensee review and

approval, test objections, prerequisites, special initial

conditions (if required), test date recording requirements,

technical content as compared to system prints and logic

diagrams, and system return to normal. The following pre-

operational and supplemental test procedures were reviewed:

,

Test Procedure (TP) 300/0, Startup and Test Generic

--

Instrument Procedure (loop calibration of OTSG level

instruments);

TP 300/0.1, EF-V-30A, EF-V-308, EF-V-30C, and EF-V-30D,

--

Control Testing;

TP 332/1, Functional Test for Pressure / Temperature

--

Compensation of 0TSG Level Indication; and,

TP 332/2, HSPS Logic Test.

--

5.2.1.2

Findings / Conclusions

!

The above review indicated that the procedures as written

would adequately test the HSPS and provided sufficient

overlap of the various tests involved to ensure that all

i

portions of the system would be tested.

One preoperational test, TP 332/3, HSPS Functional, was in

the early draft stage.

The inspector discussed the test

,

!

philosophy with the Startup and Test (SU&T) engineer and

briefly reviewed the rough draft of the procedure.

The

,

inspector was satisfied that, if written and approved as

the SU&T engineer stated, that the test would fully func-

,

tionally verify system operation. The inspector also dis-

cussed testing to verify the back-up HSPS power supply.

The SU&T engineer agreed to incorporate a functional test

of the back up power supply in TP 332/3.

The above is un-

resolved pending the drafting of and NRC review of tech-

nically complete HSPS functional test, TP 332/3 (289/

87-06-07).

l

,

l

,

- -

_

. . . - ,

- _ _ _ ,

, , - - - . . -

_ _ . - - - - - - -

.

.

- - - - - - - - - - . .

.

26

During the review of TP 332/2, which had been completed,

but had not been through the licensee's results review and

approval cycle, the inspector noted what appeared to be an

inconsistency in the 10 CFR 50.59 review policy. When dis-

cussed with the licensee, it was noted that the procedure

the inspector was reviewing had not had its results re-

viewed and the inconsistency would have been identified and

corrected.

The inspector noted that this item was pre-

viously identified (289/86-17-05 and 289/86-17-06) and is

in the process of being resolved.

5.2.2

Heat Sink Protection System Test Witnessing

5.2.2.1

Criteria and Scope of Review

Testing witnessed by the inspector included the following

observations,

including the crew's overall performance:

approved procedure with latest revision available and

--

in use by test personnel;

--

a designated person in charge and conducting the test;

minimum test personnel requirements met;

--

qualified personnel performing the test;

--

test

precautions

followed and prerequisites met;

--

--

QA/QC notification and witness requirements met (QA

engineer present as required);

proper plant supporting systems in service;

--

special test and measuring equipment required by the

--

test procedure, its calibration, and use;

procedure is technically adequate for the test;

--

testing being performed as required by the test

--

procedure;

test personnel actions were correct and timely during

--

performance of the test; and,

adequate communications established for test perform-

--

ance.

. ::

%

27

5.2.2.2

Findings and Conclusions

5.2.2.2.1 TP 300/0.1, EF-V-30A, EF-V-30B, EF-V-30C, and EF-V-300,

Control Testing

.

The inspector observed several portions of TP 300/0.1 which

proceeded without problem and in accordance with the above.

During Section 9.3, Test Valve Control, manual control of

the valves was attempted from the control room.

Three

valves stroked properly; however, the

"C"

valve failed to

operate. The SU&T engineer troubleshot the control circuit

and had control transferred to the remote shutdown (RSD)

panel.

The

"C" valve could be controlled from the RSD

panel.

Control was then transferred back to the control

room and the "C" valve could then be properly controlled.

This matter was discussed with the licensee, who agreed to

gather information concerning the transfer relays and would

then initiate a Field Questionnaire for Technical Function

resolution. Resolution of this item will be followed dur-

ing a routine inspection.

5.2.2.2.2 TP 332/1, Functional Test for Pressure / Temperature

Compensation of OTSG Level Indication

The inspector observed a portion of the performance of this

test on February 24, 1987.

Further testing was suspended

until some new modules (median level - selector module),

which were not expected to be delivered in time to be

installed, were received.

The installation of the new

modules negated a large portion of the testing already

accomplished under TP 332/1. Retesting of the HSPS was in

progress at the end of the inspection.

5.2.3

Appendix R Modifications, Testing, and Procedure Review

5.2.3.1

Criteria and Scope of Review

The criteria and scope of review for Appendix R modifica-

tions test procedure review and test witnessing are as

stated in paragraph 5.2.2.1 above.

5.2.3.2

Findings / Conclusions

During the Cycle 6 refueling outage, a large number of

Appendix R modifications are being made such as replacement

of regular cable with fire retardant cable, rerouting of

cables, separation of cables, and installation of modifica-

tions necessary to support a remote shutdown panel.

l

!

I

-

-

-.

.

-~

-

.

.-

.

_ ..

I

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28

The modifications are being administrative 1y controlled by

a tie-in document which is controlled by the control room

operators. The document controls each phase of the modiff-

cation beginning with installation through testing and QC

verification prior to return to operation.

Technical aspects are implemented by procedure No. 1420-

EL-2, Revision 4, Preoperational Startup Testing of Elec-

trical Equipment.

This procedure gives guidance and re-

quirements covering twenty-eight different tests depending

on the modification. The inspector discussed the implemen-

tation of testing with the cognizant SU&T engineer.

The

engineer explained that some modifications receive more

extensive testing than that recommended by 1420-EL-2. These

modifications are tested under supplemental tests which are

in greater detail and are developed for a specific modifi-

. cation. The inspector reviewed two Appendix R modification

preoperational test procedures and witnessed major portions

of their performance. The following were reviewed:

TP 422/1, Emergency Diesel Generator Functional Test;

'

--

and,

TP 400/0.3, Containment Building Chilled Water Pump.

--

,

,

J

Both modifications were made to allow control of the re-

spective component to be transferred to the local area

(remote from the control room) for shutdown outside the

control room, which are Appendix R requirements.

TP 400/0.3 proceeded smoothly with only minor problems

,

which were immediately corrected.

During TP 422/1, the

-

operations staff was directed to electrically strip and

de-energize the Emergency Diesel Generator (EDG) "B" bus.

'

In addition, the operators removed the fuse in the 125 V

d.c. control circuit for the undervoltage relay to prevent

losing the 480 V a.c. bus when the 4160 V a.c. bus was de-

energized.

This prevented the EDG breaker from being

closed at the remote location when required by TP 422/1.

i

This initially caused some confusion and testing was sus-

pended to review the EDG breaker schematic.

It was deter-

mined that the undervoltage relay must energize to allow

.

breaker closure on a loss of power or from the remote con-

trol location.

The test procedure was modified to allow

t

.

the undervoltage relay contact in the EDG breaker closing

'

circuit to be jumpered.

The test was then successfully

completed. QA/QC coverage was provided during both tests.

l

I

!

_ _ _ _ _ _

- _ _ _ _ _ _ _

_ _ _ _ _ _ _

_ _ _ . . _ _ , _ _ _ _ _ ~

_ _ _ _ _ , _ , _ _

_ --_

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

_ _ _ _ _ _ __ ____ - -

!

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29

5.2.4

General Preoperational Test Findings / Conclusions

The team found the technical support personnel (design and

t

test engineer) were knowledgeable of their assigned equip-

ment, current problem on related work activities, and dedi-

cated to performing meaningful tests to ensure correct

system / component function.

Resources in the startup and test department appear to be

strained.

During periods of routine operation or minor

outage modification, the number would be adequate. During

this outage, there were a large number of modifications

being made, and subsequently, a great deal of testing. The

high level of activity and long hours were beginning to

show in the test engineers talked to by the inspectors and

.

is a contributing factor in the late production of TP

332/3.

No other adversities were noted.

No procedure

inadequacies were noted as a result of this.

(

5.3 Summary of Findings (Modification and Test Control)

,

In the mechanical / structural area, the inspector noted that the fol-

lowing work / analysis had not been completed.

Single failure analysis associated with MS-V-6 (see Section 2 of

--

this report).

HELB analysis was under review and has not been completed

--

(paragraph 5.1.2.2).

MS-V-6 air controller seismic study (paragraph 5.1.2.2.)

--

A walkdown to determine the acceptability of the seismic Cate-

--

gory 2 over seismic Category 1 interaction has not been docu-

mented by the licensee (paragraph 5.1.2.6).

The licensee acknowledged that these mechanical / structural analyses

are required to be completed prior to restart of the unit and this

area remains unresolved pending completion of licensee action and

further NRC:RI review (289/87-06-08).

In the electrical / instrumentation area, the inspector noted:

FMEA has not been completed; this study is necessary to estab-

--

.

lish that single failure requirements have been met (paragraph

5.1.2.2);

coordination study for safety-related a.c. and d.c. protective

--

devices has not been completed (paragraph 5.1.2.3);

_ _____ __

i

?

t-

30

,

,

voltage drop calculations for HSPS circuits have not been com-

--

pleted to determine that equipment minimum voltage requirements

have been met or identified by the licensee to be required

(paragraph 5.1.2.3);

.

HSPS loop error calculation is inadequate and needs to be redone

--

to establish valve setpoints (paragraph 5.1.2.4); and,

,

wire separation in the HSPS cabinet needs to be readdressed

--

(paragraph 5.1.2.6).

The licensee acknowledged that these analyses are also required to be

l

completed prior to restart of the unit and this remains unresolved

l

pending completion of licensee action and NRC:RI review (289/86-06-09).

Configuration control documents need to be updated (289/86-14-03)

(paragraph 5.1.2.5).

.

f

The HSPS functional testing to serve as the initial surveillance test

needs to be completed and this area remains unresolved (289/87-06-06).

5.4 Overall Summary (Modification and Test Control)

The team concluded the major elements of the design of the HSPS

essentially meets TAP II.E.1.1 and II.E.1.2, and related correspond-

ence.

However, the adequacy of the final design cannot be fully

confirmed until the completion of essential design analysis func-

tional testing as noted previously.

A number of key configuration

control documents for HSPS are not yet updated but will be before

Cycle 6 startup.

l

An apparent violation was identified in that a revised HSPS setpoint

,

calculation was issued without proper review and approval. The type

l

of errors noted during the inspection indicated a need for improve-

l

ment in attention to detail on the part of licensee engineering

personnel.

!

No test procedure inadequacies were noted.

In fact, the team found

the test procedures to be generally well written and technically cor-

rect. One item identified by the team is that test procedures could

benefit from a better description of what function was intended to be

tested to allow a reviewing organization or person to more quickly

understand the test.

The testing program is organized such that design or installation

errors will be sufficiently identified and corrected.

.

..

.

_

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

i

31

The in place, tie-in document system seems to provide good control of

modification and testing activities.

However, one instance (EDG

breaker test) was noted where operations department adversely affec-

ted the smooth conduct of a test by impromptu action to solve one

problem without full evaluation of the consequences of that action.

Both problems could be solved with proper planning, communication,

and evaluation.

Management was involved with personnel conducting modification and

testing activities on a daily basis.

6.

Assurance of Quality

6.1 Criteria and Scope of Review

The inspectors reviewed the implementation of the licensee's quality

assurance (QA) program, focusing on procurement, audits, and design

control with respect to the HSPS system.

In their review, the

inspectors utilized technical specifications (TS), Quality Assurance

Plan (QAP), and related ANSI Standards as acceptance criteria; and,

more specifically, they reviewed the documents listed in Attachment

2.

6.2 Findings / Conclusions

6.2.1

Procurement

Procurement was being performed by procedures set forth

within the Quality Assurance / Quality Control (QA/QC) docu-

ments.

The inspector identified that the microfilming of

purchase orders did not produce a clarity that was easily

readable; however, the licensee does file the original

document in another area.

The inspector concluded that,

although a document is available for review, there does not

seem to be much wisdom of microfilming documents that are

unreadable and keeping the original document. The licensee

should research this area to make the necessary corrections

for a more efficient system.

6.2.2

Audits

Audits are being performed on a scheduled basis; however,

audits related to the HSPS system, which is where this

inspection was concentrated, have not been completed. The

inspector had a meeting with the corporate and site audit

teams and discussed the methods and findings that have been

completed to date. The inspector concluded that a thorough

review had been done by the corporate audit team and that

the audit had identified the following findings dealing

with incomplete analyses or documentation that were of

significance.

!-

1

t

i

32

Failure Modes and Effects Analysis (FMEA)

--

High Energy Line Break Analysis (HELB)

--

!

Seismic study associated with MS-V-6

--

Single failure analysis associated with backup instru-

--

ment air

l

l

These are discussed in detail in Section 5 of this report.

This is reasonable since the audit process is a sampling

technique. The documentation of the above-noted corporate

audit is unresolved pending licensee issuance and subse-

quent NRC:RI review (289/87-06-10).

l

Similarly, the inspector noted that site audits had iden-

l

tified findings and the more significant ones have been

corrected.

Completed audits related to the outage have

been reviewed and no adverse findings were identified.

6.2.3

Design Control

Design control is being performed in accordance with the QA

program.

The NRC inspector concluded that QC presence is

evident at the job site where work is being performed. The

j

licensee's QC inspectors delineate their observations for

the various witness and hold points in a QC notebook or

they can be recorded on QC witness / hold point forms gener-

ated by QA engineering during modification document review.

The NRC inspectors observed in one particular case QC per-

sonnel verifying data being recorded for HSPS logic testing

per TP 332-1.

A data sheet in this particular procedure

contained a signoff for QC personnel to list their observa-

tions; but, even though QC coverage was evident, no signoff

or test observations were made on the official test docu-

ment.

The inspectors discussed the method of establishing hold

and witness points with QC/QA management personnel.

The

!

inspectors verified that hold and witness points were

established for various work, surveillances, and test eval-

uations in a formal manner.

In the specific case noted

above for TP 332-1, however, it appeared that documentation

of the QC inspection results could have been included in

the actual test document.

Licensee QC/QA management indi-

cated that they would review this matter.

The inspectors

concluded that a program for establishing hold and witness

points was established and properly implemented.

I

I

33

6.2.4

General QA Department Findings

The inspectors, did not have any adverse findings in the

review of the QA department.

The licensee management

should address the duplication process used in the reten-

tion of purchase orders and the microfilming of the same in

order to obtain a more efficient method of documentation of

purchase orders.

Overall, the inspectors found the QC/QA organization to be

knowledgeable of the design changes and informed as to

plant conditions.

The organization appeared to be well

staffed with knowledgeable

and experienced

personnel.

6.2.5

Procedures for Startup

The team noted that, especially in the functional areas of

plant operations and surveillance, there was a substantial

amount of procedure revision work remaining to be completed

before startup. Based on a sampling review, the team con-

cluded that, in all functional areas, there was a reason-

able list of affected procedures as a result of modifica-

tion (primarily HSPS) and TS amendments (Nos.101 to 121).

The NRC's TMI-1 Resident Office will selectively review the

results of the licensee's effort in this area in a future

inspection.

6.2.6

Technical and Safety Process for Startup

As noted in Section 7, the NRC staff identified several

issues with the licensee's technical and safety (T&S) re-

view process. These issues centered around improper imple-

mentation and adequacy of the process required by 10 CFR 50.59.

In conjunction with this inspection, a followup

inspection occurred as a result of the management meeting

held February 12, 1987, (re:

NRC Inspection Report 289/

87-04). The focus of this inspection was to assure suffic-

ient interim corrective measures were established by the

licensee for safety considerations associated with the

l

Cycle 6 startup until the general issues were resolved

!

between NRC staff and the licensee,

i

The inspector learned that TMI-1 division had established

for startup an interim policy that all important-to-safety

.

procedure / procedure changes would be subject to the licen-

see's two-step review process.

This two-step review pro-

cess (re:

NRC Inspection Report 50-289/86-17) meets the

,

requirements of the TS and 10 CFR 50.59.

I

1

I

i

34

The inspector then noted that support divisions at TMI-1

were in line with the corporate policy on T&S review, which

may be deficient when only the first step of the two-step

process

is used for important-to-safety changes.

The

initial step, however, does query the reviewer on the ef-

fect of the change to plant safety and as to whether or not

TS or FSAR changes are needed.

The inspector considered this situation to be adequate for

Cycle 6 startup pending resolution of the general issues

between NRC staff and the licensee (re:

Unresolved Item

Nos. 289/86-17-05 and 86-17-06).

Within the other functional areas addressed by this report,

the team noted several discrepancies,

In the design control area, the revision to the HSPS

--

safety evaluations was misleading in terms of who per-

formed

Responsible

Technical

Reviewer / Independent

Safety Reviewer (RTR/ISR) review of the revision.

Further, the 1984 10 CFR 50.59 form had 1984 signa-

tures for Revision 1,

dated 1986.

Also, there was

incomplete documentation to confirm consideration of

all safety evaluation elements / considerations in the

revised narrative pages of the safety evaluation.

In the testing area, test activities on HSPS were

--

misclassified as not important to safety apparently

because of the poor understanding of the corporate

policy which tends to de-emphasize the not-important-

to-safety /important-to-safety (NITS /ITS) classifica-

tion methodology.

With the preoperational test pro-

cedures to represent the initial surveillance proce-

dures for HSPS, the inspector stated that those test

procedures (TP's) are subject to the same TS LCO/

surveillance and administrative control requirements

as

their surveillance

procedure

(SP) counterpart

tests.

No technical inadequacies or safety issues resulted from

these discrepancies, although the potential could exist in

cases of incomplete documentation as noted above.

These

examples continue to point out lack of thorough documenta-

tion of records required by 10 CFR 50.59 and TS and to

reflect that the new policy on T&S review was not clearly

understood at all working levels. This area will continue

to be reviewed under the previous unresolved item (289/

86-17-06).

o

,

!

!

35

6.2.7

Other Management Control Issues

The team noted a number of residual issues as a result of

NRC Inspection No. 50-289/86-23 on licensee implementation

of 10 CFR 50 Appendix R, Fire Protection Rule. There are

at least two exemption requests that need to be approved by

NP,C staff prior to startup and a number of licensee commit-

ments need to be completed before Cycle 6 startup. As an

example, the integrated functional test procedure for the

remote shutdown panel is being written and will be per-

formed prior to Cycle 6 startup.

The team noted no new

discrepancies in this area ind it was satisfied that the

resolution of these issues coJ d be adequately addressed by

Region I, the Resident Office, nd/or the Office of Nuclear

Reactor Regulation.

The team also noted a number of residual issues as a result

of NRC Inspection 50-289/87-01 on licensee implementation

of 10 CFR 50.48 on Environmental Qualification.

At the

exit interview for that inspection, the licensee initially

committed to meet with Region I to discuss, if any, of the

(equipment qualification) EQ file deficiencies warranted

hardware changes prior to Cycle 6 startup.

Subsequent to this inspection, the meeting was held at NRC

Region I and it will be documented in a separate meeting

report.

6.2.8

prerequisite List

The team reviewed the "TMI-1 Post 6R Refueling Outage

Restart Prerequisite Review Changes," which was written by

the licensee to ensure management personnel responsible for

completing prerequisites are cognizant of their items need-

ing completion prior to criticality.

The team inspectors

had discussions with licensee management to discuss the

above document.

The licensee indicated that this control

had been used effectively in the past. The licensee man-

agement concluded that a very good confidence level will be

attained prior to criticality. The " tie-in" document sys-

tem has been put in place to control a modification through

the process of testing QA review and final acceptance to

the plant. The team concluded that the prerequisite list

and tie-in documents should be effective, if properly

.

implemented, in assuring the safe restart of the unit.

i

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t

i

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I

36

6.2.9

Training

Based on past good licensee performance, this area was not

specifically reviewed.

However, the team inspectors re-

mained conscious of this area within their respective func-

tional areas to look for obvious deficiencies related to

the training of licensed and non-licensed personnel.

A

summary of the team's view of this area is presented below.

Overall, the team concluded favorably in regard to training

of personnel for the modifications that were installed dur-

ing this outage. As an example, extensive training is in

progress for the two primary modifications of this outage:

HSPS and the remote shutdown panel.

In addition to class-

room sessions, plant walkthroughs and easy-to-read handouts

were provided to licensed operators.

The results of' team interviews with licensee representa-

tives indicated that they were knowledgeable of the basic

design elements of these modifications.

Planned testing

should enhance personnel knowledge of these new systems.

Licensec management recognized the need to complete the

specific training plan prior to plant startup.

In conjunction with this inspection, there was another

Region I inspection in progress on the licensee's requalif-

ication process (NRC Inspection No. 50-289/87-03).

The

team leader provided the NRC licensing examiners, conduc-

ting that review, with specific examples for followup

related to recent facility changes.

6.3 Summary

Procurement is appropriately controlled. Poor quality of microfilmed

procurement records is backed up by hard copies.

There is a significant amount of in-line process inspection (quality

control) by the Quality Assurance Department (QAD) for modifications.

The c.orporate audit on four specific modifications and other on-site

installation audits ware reasonably thorough to assure overall proper

implementation of the modification and testing control program.

Audit reports need to be issued.

A majority of audit findings on

HSPS were similar to NRC findings in this inspection.

The QAD is

well staffed with experienced personnel who are knowledgeable in

their respective areas.

';-

1

37

The licensee has a substantial effort in progress to revise proce-

dures potentially affected by outage modifications and recent TS

amendments.

The list of procedures to be revised appears to be

reasonably complete.

The T&S review process for the TMI-1 Division is adequate. The cor-

porate policy for T&S remains unclear and, apparently, is not well

understood by licensee personnel.

The adequacy of the corporate

policy remains unresolved with the NRC staff.

A number of actions are needed to be completed by the licensee before-

startup to assure compliance with the NRC's environmental qualifica-

tion and fire protection rules.

The licensee's "TMI-1 Post 6R Refueling Outage Restart Prerequisite

Review Change List" is a substantial initiative to provide the licen-

ee with the necessary requisite assurance of readiness for TMI-I

startup.

7.

Previous Inspection Items

7.1 (Closed) Unresolved Item (289/85-12-01): Adequacy of Installation

of Post-Accident Sampling (PASS) Station Handwheels

A review of TMI-1 Licensing Action Item No. 9196 indicated that all

loose Post-Accident Sampling System (PASS) handwheels were subse-

quently tightened by plant maintenance. Also, a weekly valve post-

tion check of the PASS includes a verification of the tightness of all

associated handwheels.

Discussions with the on-site senior chemist

and a visual inspection at the PASS by the inspector indicated that

no further problems have been encountered with the PASS valve hand-

wheels.

7.2 (0 pen) Unresolved Item (289/85-20-01):

Safety-Grade Emergency

Feedwater Installation

A review was performed to identify the residual issues open in TAP

II.E.1.1 and II.E.1.2 as previously documented in NRC Inspection

Report (IR) No. 50-289/85-20.

All issues have been inspected and

found acceptable with the exception of the following: (1) EFW pipe

support modification in the reactor building (IR No. 50-289/87-02);

(2) system interaction study (IR No. 50-289/86-21 and 87-02); (3) EFW

Control and Block Valve (IR No. 50-289/87-03); (4) safety grade power

for CO-V-111A/B and upgrade cable for CO-V-14A/B (IR No. 50-289/

.

86-21); (5) environmental qualification for EFW and ES power, con-

trol, and instrument cables in the intermediate building (IR No.

50-289/87-01); and, (6) condensate storage tank level and low level

alarm (IR No. 50-289/86-21 and 87-02).

However, in each instance,

there has been a partial review by the NRC staff as noted in appit-

cable inspection reports listed above.

In each case, the open issue

has been completed by the licensee or is scheduled to be completed

,

j

prior to plant startup in March 1987.

1

,

l

38

l

!

From the sampling review of licensee's documentation and previous

inspection reports, the inspector concluded that it appeared that the

licensee had completed all requirements of Restart License Condition

3(a) as described,in Section 5 of this report.

Final determination

requires additional review by the NRC staff to verify the comalete-

ness and adequacy of the licensee's documentation on the above six

i

issues and others as delineated in the recent NRC staff SER for TAP

Item II.E.1.2.

l

7.3 (Closed) Unresolved Item (289/86-03-19): Adequacy of Pipe Support

'

EF-18 Installation

A review of TMI-1 Licensing Action Item No. 86-9165 indicated that

blanket Job Ticket (JT) No. 86-56 was initiated to correct the dis-

'

crepancy on pipe support EF-18. A general review of other area sup-

ports was conducted by the licensee to identify whether or not any

other pipe support discrepancies existed.

No additional discrepan-

cies were identified. A visual inspection of pipe support EF-18 by

the inspector verified that EF-18 was installed correctly.

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7.4 (Closed) Inspector Follow Item (289/86-03-20): Human Factors

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Placement of EFW Manual Isolation Valves

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The inspector walked down selected portions of the EFW system. He

confirmed that in the post-outage modification configuration there

were no obstacles that may obstruct manual operation of the EFW flow

control valves (EFW 30A through D) or operation of the manual isola-

tion valves on their discharge. The valves were also relatively easy

to reach. With control room permission and as supervised by an aux-

iliary operator, the inspector manually opened and closed one of the

EFW 30 valves which had a support bracket located approximately 10

inches above the valve handwheel. The bracket did not interfere with

valve operation.

j

7.5 (Closed) Inspector Follow Item (289/86-09-02): Installation of

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480-Volt a.c. Breaker Solid State Overcurrent Trip Devices

l

The trapec+6r reviewed the status of the installation of solid state

overcurrent trip devices for 480-volt a.c. breakers.

All Class 1E

l

480-volt breakers have been upgraded with the new overcurrent trip

l

devices. Time setpoint changes were necessitated as a result of this

upgrade on IP-4C and 15-4C breakers.

Field Change Request (FCR)

I

053027, which detailed this change, was also reviewed,

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39

7.6 (Closed) Unresolved Item (289/86-12-01): Artificial Condition

Established by Blowing Down Steam Traps Before Testing Turbine-Driven

EFW Pump

The licensee performed STP-1-86-0014 on May 23,1986, to demonstrate

that the turbine-driven EFW pump would not overspeed or have other

speed control difficulties due to the potential condensate buildup in

the steam supply lines over a period of time in which operators did

not manually verify the lack of condensate.

During this test, the steam traps were capped and blowdown of the

lines did not occur for 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> and 40 minutes. The pump was subse-

quently started with a stable acceleration to 3800 rpm and stable

operation at 3800 rpm for longer than any time required to flush

potential condensate from the steam supply line.

Based on these

acceptable test results, this item is considered closed.

7.7 (0 pen) Violation (289/86-12-02): Single Failure Analysis on EFW

Instrument Air System (in part).

See paragraph 2.2.6

7.8 (0 pen) Unresolved Item (289/86-14-03):

Drawing Control

See paragraph 5.1.2.5.

7.9 (Closed) Unresolved Item (289/86-14-05) and (Open) Unresolved Item

(289/86-17-05):

Improper Implementation of the Technical and Safety

Review Process

The second Performance Appraisal Team (PAT II) inspection documented

the misclassification of certain Special Temporary Procedures (STP's)

and technical functions procedures, which resulted in an apparently

inadequate 10 CFR 50.59 safety evaluation for these procedure /proced-

ure changes. The Region I Inspection No. 50-289/86-17 included the

PAT II finding along with additional examples of the same finding.

The PAT II also identified technical inadequacies with the subject

STP's and certain Temporary Change Notices (TCN's). The STP's were

no longer effective and the TCN's were corrected as noted in PAT II.

The subject of improved performance in the adequacy of procedures was

discussed at the recent Systematic Assessment of Licensee Perform-

ance (SALP) meeting on February 24, 1987.

Licensee planned correc-

tive action with respect to improving procedure adequacy to avoid

procedure

implementation challenges (re:

NRC Inspecticn Report

50-289/86-19) should enhance this area.

Accordingly, the PAT II unresolved item (289/86-14-05) is considered

closed administratively with Region I followup and disposition of

these findings in a future inspection (289/86-17-05).

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7.10 (Closed) Unresolved Item (289/86-14-06) and (0 pen) Unresolved Item

(289/86-17-06): Adequacy of the Current Technical and Safety

Review Process

The PAT II documented that a two-step process of safety review was

implemented as of September 1,1986.

The process was described in

detail in NRC Region I Inspection Report 50-289/86-17. The two steps

were essentially embodied in the use of two forms with the second

form having the traditional criteria to determine whether or not an

unreviewed safety question existed.

The first form was an initial

screening process for whether or not the second form was to be used.

The issue was discussed at a recent Management Meeting in Region I

(re:

NRC Inspection Report 50-289/87-04).

Region I followup and

disposition of the finding will occur in a future inspection (289/

86-17-06).

Accordingly, the PAT II unresolved item is duplicative and is con-

sidered administratively closed.

The status of current technical and safety review process with re-

spect to Cycle 6 startup was reviewed as a part of this readiness

assessment inspection as documented in Section 6.

7.11 (Closed) Unresolved Item (289/86-19-03):

Review of Procedures

Regarding Detection of High Water Level in the Intermediate Building

as an Indicator of Such Events as a Feed Line Break.

The inspector reviewed the annunciator procedure for the upgraded pit

level indication system. The procedure directed appropriate investi-

gation/ diagnostic actions.

Additionally,

the inspector reviewed

annunciators for the EFW room "A"

and

"B"

sumps.

Both called for

operator action to go to the area and investigate the cause.

8.

Exit Interview

The team discussed the inspection scope and findings with the licensee

management at a final exit meeting conducted March 3,1987. The interim

exit meetings occurred:

February 20, 1987, in the Modification Control

Area (Technical Support); and, on February 27 1987, in the Plant Opera-

tions Area.

Licensee personnel in attendance at the final exit interview

are noted below and also in Attachment 1 as denoted by an asterisk.

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R. Chisholm, Manager, Electrical Power & Instrumentation

J. Colitz, Manager, Plant Engineer, TMI-1

J. Garrison, Planning and Scheduling Manager

D. Hassler, Licensing Engineer

H. Hukill, Director, TMI-1

J. Langenbach, TMI-1 Engineering Projects Director

L. Markowicz, Representative - Media Relations

R. McGoey, Manager, PWR Licensing

L. Ritter, Administration, Plant Operations

L. Robinson, Representative - Media Relations

M. Sanford, Manager, Mechanical Systems

C. Shorts, Manager, Technical Functions, TMI-1

C. Smyth, Manager, Licensing, TMI-1

R. Toole, Operations and Maintenance Director, TMI-1

A representative of the Commonwealth of Pennsylvania, Ajit Bhattacharyya,

also attended the meeting.

No proprietary information was discussed at the exit meetings.

The

inspection results, as discussed at the meeting, are summarized in the

cover page of this inspection report.

Unresolved Items are matters about which more information is required in

order to ascertain whether they are acceptable, violations, or deviations.

Unresolved items discussed during the exit meeting are addressed in para-

graphs 2.2.3, 2.2.5, 3.2.2, 4.2.6, 5.2.1.2, 5.3, and 6.2.2.

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INSPECTION REPORT 50-289/87-06

ATTACHMENT 1

,

PERSONS CONTACTED

-

The following is a list of key licensee supervisory or management personnel

contacted during this inspection. There were other technical and administra-

tive personnel who also were contacted.

Plant Operations

D. Dyckman, Manager, Program' and Control, TMI-1

• M. Ross, Plant Operations Director, TMI-1

Maintenance

R. Harper, Corrective Maintenance Manager

D. Shovlin, Manager, Plant Maintenance

M. Snyder, Preventive Maintenance Manager, TMI-1

R. Troutman, Planning and Scheduling Manager

Surveillance

• C

Hartman, Manager, Plant Engineering

V. Orlandi, Lead I&C Engineer

H. Wilson, Supervisor, Preventive Maintenance

Modification Control

GPUN

J. Auger, PWR Licensing Engineer

B. Gan, Project Engineer

S. Kowkabany, TMI-1 Licensing Engineer

• J. Langenbach, TMI-1 Engineering Projects Director

R. Wulf, Manager, TMI Projects

Impell Corporation

D. Baker, Engineer

P. Kelley, Engineer

Preoperational Testing

• T. Hawkins, Manager, Startup and Test

C. Patton, Startup and Test Manager

J. Riddlemoser, Startup and Test Engineer

G. Tullidge, Startup and Test Engineer

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Attachment 1

2

.

Assurance of Quality

J. Fornicola, Manager, TMI QA Modifications / Operations

C. Incorvati, TMI-1 Audit Supervisor

,

R. Markowski, Manager, QA Program Development / Audit

2

• M. Nelson, Manager, Nuclear Safety

• R. Prabhakar, Quality Control Manager - TMI-1

L. Wickas, Manager, Operations QA

4

• Attended exit interview on March 3, 1987.

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INSPECTION REPORT NO. 50-289/87-06

ATTACHMENT 2

DETAILED ACTIVITIES REVIEWED

Portions of the following documents / records of activities were reviewed:

General

Technical Specifications

Operational Quality Assurance Plan

Administrative Procedures

Operations

Listed within body of the report.

Surveillance Tests

1302-5.10, Reactor Building 4 psig Channel - Performed February 11, 1987

1302-5.11, Reactor Building 30 psig Channel - Performed February 18, 1986

1302-6.3, EFW Flow Instrumentation Calibration - Performed June 17, 1986

1302-6.17, EFW Initiation - Loss of Feedwater - Performed February 1,1986

1303-11.9, Reactor Building Emergency Cooling System - Performed December 30, 1986

1301-10.1, Internal Vent Valve Inspection & Exercise - Performed December 23, 1986

1303-11.14, Reactor Building Purge Exhaust - Performed December 17, 1986

1303-11.21, Core Flooding System Valve Operability Test - Performed November 1,

1986

1303-11.39, EFW Pump Automatic Start - Performed August 27, 1986

1303-11.54, Low Pressure Injection - Performed November 2, 1986

.

? ll 1

Attachment 2

2

2

Attachment 2

Surveillance Procedures Reviewed by Amendment

Amendment No. 119, Heat Removal Capacity

--

1300-3C, Decay Heat Closed Cooling Water Pumps Functional Test,

November 3, 1986

1300-3F, Motor-Driven Emergency Feedwater Pump Functional, November 4, 1986

--

1300-G, Turbine-Driven Emergency Feedwater Pump Functional, July 15, 1985

--

1303-11.42, Emergency Feedwater Flow Test From CST, July 22, 1986

--

Amendment No.122, Fuel Handling Building Engineered Safety Feature Air Treat-

ment System

,

1301-4.1, Weekly Surveillance Checks, December 30, 1985

--

1303-5.8, Auxiliary and Fuel Handling Building Exhaust Air Treat-

--

ment, January 17, 1987

1303-5.13, Auxiliary and Fuel Handling Building Exhaust Air Distribution,

--

January 17, 1987

1303-5.14, Auxiliary and Fuel Handling Building Exhaust Air Distribution,

--

January 23, 1987

1303-5.15, Fuel Handling Building Air Treatment System Operational Test,

--

January 1, 1986

1303-11.15, Auxiliary and Fuel Handling Building Filter Efficiency Test,

--

January 19, 1987

1303-11.56, Fuel Handling Building Air Filter Efficiency Test, January 1,

--

1986

<

Amendment No.123, Regulator Control Rod Power Silicon Controlled Rectifier

Electronic Trips

1303-4, Reactor Protection System, July 11, 1985

--

. Maintenance Activities

Listed within the body of the report.

.

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Attachment 2

3

3

Attachment 2

Modification Control (Specific to the Heat Sink Protection System)

SDD-TI-424-B, Revision 4, Division I

--

-SDD-TI-424-B, Revision 2, Division II

--

GPU Logic Diagrams

--

IC-640-41-001, Revision 1

--

IC-640-41-002, Revision 1

--

IC-640-41-003, Revision 1

--

IC-640-41-004, Revision 1

--

IC-640-41-005, Revision 1

--

IC-640-41-007, Revision 0

--

IC-640-41-008, Revision 1

--

IC-640-41-010, Revision 1

--

IC-640-41-011, Revision 1

--

IC-640-41-013, Revision 1

--

IC-640-41-014, Revision 1

--

IC-640-41-015, Revision 1

--

IC-640-41-016, Revision 1

--

IC-640-42-001, Revision 0

--

IC-640-42-002, Revision 1

--

IC-640-42-003, Revision 1

--

IC-640-42-004, Revision 0

--

IC-640-42-005, Revision 0

--

IC-640-42-006, Revision 1

--

Foxboro HSPS Functional Drawings

--

84N35833 FD 0001, Revision 0, Sheet 1 of 3

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84N35833 FD 0001, Revision 0, Sheet 2 of 3

--

84N35833 FD 0003, Revision 0, Sheet 1 of 3

--

84N35833 FD 0003, Revision 0, Sheet 2 of 3

--

84N35833 FD 0003, Revision 0, Sheet 3 of 3

--

84N35833 FD 0009, Revision 0, Sheet 1 of 3

--

84N35833 A2 C017, Revision 3

--

84N35833 A2 WOO 3, Revision 3

--

Impell Drawings

--

0370-064-111, Revision 0

--

0370-064-104, Revision 2

--

0370-064-092, Revision 0

--

0370-064-001, Revision 5, Sheet 1 of 3

--

0370-064-001, Revision 4, Sheet 2 of 3

--

0370-064-001, Revision 2, Sheet 3 of 3

--

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Attachment 2

4

HSPS Loop Error Calculation 0370-129-001, Revision 0

--

Verification Plan for 0370-129-001, dated April 28, 1985

--

Field Change Request 038520

--

Field Change Request 054605

--

Technical Functions Division Procedure EP-006, Calculations

--

GPU Training Handing for HSPS (January 8, 1987)

--

Field Change Request 032720

--

--

Field Chang, Request 051202

Field Change P.equest 032728

--

Field Chang Request 051206

--

Field Change Request 051213

--

Field Change Request 051211

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Field Change Request 052405

--

GPUN Letter 5211-86-2214, dated December 23, 1986

--

SE No. 000424-004, Revision 1

--

--

SE No. 412024-004, Revision 0

--

SE No. 412024-006, Revision 1

Preoperational Testing

Listed within the body of the report.

Assurance of Quality

QA/QC Organization Chart

Post-6R Refueling Outage Startup Review List

Design Change - WA-A25C-30024

A25C-G1024E

A25C-G1024M

Procedure Documents - Purchase Order 020756 - Piping

016065 - Transmitters (Foxboro)

089145 - Cable (Mild Environment)

615426 - Cable (ITS & IEEE-323-1974)

Audit Plan 0-TMI-86-11 (corporate review of design changes related to

TMI-1 6R modifications)

Audits - S-TMI-87-01

" Refueling"

S-TMI-86-05

" Functional Audit of Safety Systems"

S-TMI-85-20

" Project Engineering (SU&T)

.