IR 05000289/1993009

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-289/93-09

ML20057A586
Person / Time
Site:	Three Mile Island
Issue date:	08/31/1993
From:	Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Broughton T GENERAL PUBLIC UTILITIES CORP.
References
NUDOCS 9309150011
Download: ML20057A586 (2)

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AUG 3 1 1993 Docket No. 50-289 Mr. T. Gary Broughton Vice President and Director, TMI-l GPU Nuclear Corporation Three Mile Island Nuclear Station P. O. Box 480 Middletown, Pennsylvania 17057-0191

Dear Mr. Broughton:

SUBJECT: INSPECTION REPORT 50-289/93-09 This letter refers to your May 21,1993 correspondence, in response to our April 14, 1993 letter.

Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.

Your cooperation with us is appreciated.

Sincerely, CW'sJ@

A. Randolph Blough, Chief Projects Branch No. 4 Division of Reactor Projects cc:

R. E. Rogan, TMI Licensing Director M. J. Ross, Operations and Maintenance Director, TMI-l J. Fornicola, Licensing and Regulatory Affairs Director TMI-l Licensing Department E. L. Blake, Jr., Esquire TMI-Alert (TMIA)

Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Pennsylvania 141122 9309150011-930831 D'

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ADOCK 05000289 PDR DM

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Region I Docket Room (with concurrences)

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GPU Nuclear Corporation l MNuclear "X'= #"'"

Midsetown, Pennsylvania 17057 048'-

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Writer's Disect Dial Number:

717-948-8005 May.21, 1993 C311-93-2076 j U. S. Nuclear Regulatory Comission Attn: Document Control Desk '

Washington, DC 20555 Oear Sir: ,

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Three Mile Island Nuclear Station, Unit 1 (TMI-1)

Operating License No. DPR-50 Docket No. 50-289

" Reply to a Notice of Violation" - Inspection Report 93-09 Enclosed is the GPU Nuclear reply to the Notice of Violation transmitted as Appendix A to inspection Report 93-09.

Sincerely, AW T.G.Bbughton Vice President and Director, TMI-1

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MRK Attachment cc: Region I Administrator, NRC 5enior Project Manager, M I-1, NRC '

Senior Resident Inspector, TMI-1, NRC 9 % 60 /6 % G-GPU Nudaar Corporation is a subsidiary of General Public Utilitkm Corporation

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AUG.17 '93 13:07 NRC TMI MTD PA P03

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C'il1-93-2076 Attachment C Page 1 of 2 Notice of Violation Technical Specification 6.8.1 requires that written procedures be established, implemented and maintained for the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2 February 1978.

Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978, item 3, requires that instructions for the operation of safety related systems such as the service water system (decay heat river water system) should be written to control startup, shutdown, and changing modes of operation.

Contrary to the above, the licensee failed to adequately establish and maintain Operations Surveillance Procedure $227, "DR-P-1A/B Periodic Surveillance," to .

periodically operate the decay heat river water system pumps to minimize the silt buildup under the pump suction bowls. This deficiency resulted in both decay heat closed cooling water heat exchangers, OH-C-2A/B[ sic), being isolated and bypassed for approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 55 minutes.

This is a Severity Level IV Violation (Supplement I).

Q GPU Nuclear Resoonse to the Notice of Viol _ation This Notice of Violation (NOV) is related to an event which resulted when an Auxiliary Operator (AO) bypassed river water from both Decay Heat Service Coolers (DC-C-2A/8) affecting both trains of the Decay Heat Closed Cooling Water System.

The details of this event were reported in Licensee Event Report (LER)93-002 which was submitted to the NRC on March 5, 1993. While the NOV cites a failure to establish and maintain the procedure used by the AO, the root cause of the event, as stated in the LER, was personnel error. To a lesser extent, inadequate procedural guidance contributed to the event. Therefore, it is noteworthy that GPU Nuclear actions in response to the event address a broader scope than that encompassed in the NOV.

I. Reason for the Violation ,

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The Operations (OPS) Surveillance Program [ Administrative Procedure (AP) I 1016), unitka the Technical Specification Surveillance Testing Program

[AP 100L7f, is not intended to satisfy specific regulatory requirements. The

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intent of the OPS Surveillance Program is to address items necessary to satisfy data collection requirements to support performance evaluations and station reporting needs and to provide added assurance that plant components and systems are being inspected, tested, and operated efficiently and safely.

AP 1016, Revision 19 (in effect at the time of the event) stated that detailed procedures and guidance for evolutions which could potentially affect safe and/or reliable plant operation shoul.d be contained in approved D operating procedures rather than in OPS Surveillance Procedures. plant Therefore, administrative controls discouraged but allowed the inclusion of such l evolutions in the OPS Surveillance Procedures. To meet the requirements of l Technical Specification 6.8.1, Revision 19 of AP 1016 required that certain OPS Surveillances be reviewed by the PRG and approved by the Plant Operations

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AUG.17,'93 13308 NRC TMI MTD PA PO4

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C311-93c2076 Attachment y Page 2 of 2 Director and the. Director Operations and Maintenance. The additional review and approval was applied to nuclear safety related OPS Surveillances that 1) perform a function which could compromise Technical Specification operability or 2) perform functions which operate components in a manner not previously reviewed by the Plant Review Group (PRG) in the affected system's operating Procedure (OP); this additional review and approval was applied to OPS-S227. Although AP 1016 required the same review and approval for nuclear safety related OPS Surveillances as are required for the ops, the OPS Surveillance Procedures received only infomal periodic reviews. The requirement for a biennial review in accordance with AP 1001A " Procedure Review and Approval," was not applied. ,

The reason for the violation was that actions which had the potential to :

affect safe plant operations were contained in an OPS Surveillance procedure ,

which did not receive a formal biennial review. Further, the procedure I contained provisions that are not applicable to the current plant operating conditions (i.e., provisions for bypassing river water to the Decay Heat Service Coolers to avoid a thermal transient to the Reactor Coolant System as could have occurred during the extended shutdown of TMI-1 when the decay heat generation rate was very low).

II. Corrective Steos That Have Been Taken and the Results Achieved Administrative Procedure (AP) 1016, " Operations Surveillance Program," has been revised. AP 1016 Revision 20 (Effective 4/27/93) now states that detailed procedures and guidance for evolutions which could potentially affect safe and/or reliable plant operation shall be contained in approved plant operating procedures. Performance of functions which could compromise the Technical Specifications operability requirements have been removed from the OPS Surveillance Program.

OPS Surveillance Procedure actions that could potentially affect safe plant operations in a manner similar to OPS-5227 have been relocated to an OP.

III. Corrective Steos.That Will Be'Taken to Avoid Further Violations GPU Nuclear believes that no additional action is required to address the specifie violation cited in Inspection Report (IR) 93-09. Actions committed to the IRC in LER 93-002 will be completed by May 1993 including a comprehensive review of the OPS Surveillance Procedures. As a result of GPU Nuclear review of the OPS surveillances, other recommended enhancements unrelated to the specific concerns of this event have been identified; the review may also identify more procedural material that will be relocated to an OP. Any additional changes will be incorporated by June 15, 1993.

As a result of the event discussed in LER 93-002, improvements beyond the scope of the violation cited in IR 93-09 are being made which will enhance and y reinforce the performance standards for operations personnel.

IV. Date of Full Complianqg GPU Nuclear believes that full compliance has been achieved.

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