IR 05000289/1998006

Ack Receipt of 981112 & s Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-289/98-06 .Action Does Not Change NRC Determination That Change to Hpis Valve Configuration Involved URI

ML20205E615
Person / Time
Site:	Three Mile Island
Issue date:	03/26/1999
From:	Lanning W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Langenbach J GENERAL PUBLIC UTILITIES CORP.
References
50-289-98-06, 50-289-98-6, EA-98-456, NUDOCS 9904050237
Download: ML20205E615 (3)

Text

y, e March 26, 1999

' EA 98-456 Mr. 'J. Langenbach Vice President and Director GPU Nuclear, Inc.-

Three Mile island Nuclear Station '

P. O. Box 480 -

Middletown, Pennsylvania 17057-0480 SUBJECT: NRC INSPECTION NO. 50-289/98-06 (REPLY)

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. Dear Mr. Langenbachi This letter refers to your November 12,1998, and December 24,1998, correspondence in response to our October 15,1998 letter. Our letter transmitted a Notice of Violation for a violation classified at severity level IV fo'r a change to the facility, that involved an unreviewed safety question, which was implemented without prior NRC approval. The change involved opening cross connect valves MU-V69A and MU-V69B, which altered the configuration'of the suction lines of the high pressure injection pumps. .This change created the possibility for a malfunction of a different type than any previously evalcated in the UFSAR in that the potentici existed for failure of the "C" makeup pump due to gas entrainment from the makeup tank.

In your safety evaluation to support that change. you failed to consider the effects of a failure of either BWST supply valve MU-V-14A or MU-V-14B to open under a design basis accident scenario with offsite power available. Consequently, the existing makeup tank operating pressure / level curve in procedure 1104-2, " Makeup and Purification System," was not adequate

~ to support proper system operation during that design basis scenario. The inadequacy created )

the potential for gas entrainment in the suction of the "C" makeup pump if all three makeup l pumps were running and one of the BWST supply valves, MU-V-14A or MU-V-14B, failed to l open. I In your correspondence dated November 12,1998, you admitted the violation, described the reason for the inadequate pressure / level curve,- and provided corrective and preventive actions taken and planned to prevent recurrence. In your correspondence, dated December 24,1998, // 3

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you provided your justification for continued operation with the cross-connect valves open in g

light of the fact that the original licensing basis for the high pressure injection system considered l

the valves to be closed to maintain train separation. Although you have taken corrective action /

to revise the makeup tank pressure /ievel curve, this action does not change the NRC's f determination that the change to the high pressure injection system valve configuration involved >

an unreviewed safety question. We have reviewed yourjustification for continued operation and have e aciuded that operation with the cross-connect valves open does not represent an immediate safety concern. However, changing the high pressure injection system cross-connect valve configuration created the possibility for an accident of a different type than any )

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9904050237 990326 )

PDR ADOCK 05000289 )

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J.Langenbach 2 previously analyzed in the UFSAR regardless of the makeup tank pressure / level curve inadequacy in that opening of the valves created the possibility for a common failure of all three makeup pumps. The original TMI high pressure injection system safety evaluation that addressed the common cause failure of the high pressure injection was based on the maintenance of train separation. As such, NRC review and approval of the change is required in accordance with 10 CFR 50.59.- Please coordinate with Timothy Colbum, the TMI NRR

. Project Manager, as to when a submittal will be forthcoming.

If you have any questions regarding this matter, please contact Jimi T. Yerokun of my staff at (610) 337-5108.

Your cooperation with us is appreciated.

Sincerely, Wayne D. Lanning, Director Division of Reactor Safety Docket No. 50-289 cc:

M. J. Ross, Director, Operations and Maintenance j D. Smith, PDMS Manager M. Laggart, Manager, Licensing and Vendor Audits J. Wetmore, Manager, Nuclear Safety and Licensing E. L. Blake, Shaw, Pittman, Potts and Trowbridge (Legal Counsel for GPUN)

TMl-Alert (TMIA)

Commonwealth of Pennsylvania

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J.Langenbach 3 Distribution w/ encl:

Region l Docket Room (with concurrences)

Nuclear Safety information Center (NSIC)

PUBLIC NRC Resident inspector P. Eselgroth, DRP N. Perry, DRP C. O'Daniell, DRP W. Lanning, DRS W. Ruland, DRS J. Yerokun, DRS D. Holody, ORA DRS File t M. Tschiltz, OEDO E. Adensam, PD1-2, NRR T. Colburn, PD1-2, NRR R. Eaton, PDl-2, NRR R. Correia, NRR DOCDESK Inspection Program Branch, NRR (lAS)

DOCUMENT NAME: G:\SUPPORTTYEROXUN\TMl9806R.WPD To receive a copy of this dg tment. Indicate in the box: 'C' = Copy without attachment / enclosure "E" = Copy with attachment / enclosure

"N" = No copy OFFICE Rl/DRS Rl/DRP Rl/ORAgj HQ/NRR

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NAME JYerokun 6IP WSchmidtvJ6 DHolodyL TColburn f/'f__ WL7nnYng DATE 03/17/99 03/n/99 03h/99 03/6199 ffW ' OMl//99 OFFICIAL RECORD COPY / l

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I GPU Nuclear, Inc.

(. Route 441 South NUCLEAR Post Office Box 480 Middletown. PA 17057 0480 Tel 717-944 7621 November 12, 1998 1920-98-20654 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Wasidagton, D. C. 20555 Gentlemen:

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

Operating License No. DPR-50 Docket No. 50-289 Reply to Notice ofViolation Reference: NRC Letter dated October 15,1998 "NRC Inspection Report No 50-289/98-06 and Notice of Violation" The referenced letter enclosed a Notice of Violation in regard to a change to the makeup system cross-connect valves. Pursuant to the provisions of10 CFR 2.201, Attachment I to this letter provides the GPU Nuclear response to the Notice of Violation.

Sincerely, v & k Yi y -

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s ames W. Langenbac Vice President and Director, TMI MRK Attachments cc: TM1 Senior Resident inspector

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TMI-1 Senior Project Manager

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c Region Administrator, File No. 97062

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1920-98-20654'

- Attachment 1 Page1of2 NOTICE OF VIOLATION GPU Nuclear Corporation Docket No. 50-289

' Three Mile Island Nuclear Station License No. DPR-50 l

EA No.98-456 1 During an NRC inspection conducted between August 10 and 27,1998, a violation of NRC ,

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requirement was identified. In accordance with the " General Statement of Policy and Procedure j for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

10 CFR 50.59 states, in part, that changes to the facility as described in the safety analysis report may be made without prior NRC approval, unless the proposed change involves a change in the technical specifications incorporated in the license or an unreviewed safety question. A change shall be deemed to involve an unreviewed safety question if a possibility for malfunction of a different type than any evaluated previously in the safety analysis report may be created.

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Contrary to the above, in October 1997, a change to the facility as described in Section 6.1, Emergency Core Cooling systems, of the TMI-1 Updated Final Safety Analysis Report (UFSAR),

involving an unreviewed safety question, was made without prior Commission approval. The change, which involved cross connecting the previously separate suction lines of the three high pressure injection pumps by opening valves MU-V69A and MU-V69B, created the possibility for a malfunction of a different type than any previously evaluated in the UFSAR in that a new potential for failure of the "C". makeup pump due to gas entrainment from the makeup tank was created.

This is a Severity Level IV violation (Supplement 1)

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GPU NUCLEAR RESPONSE TO THE NOTICE OF VIOLATIOE GPU Nuclear acknowledges that the violation occurred as stated in the Notice of Violation presented in NRC Inspection Report No. 50-289/98-06.

Reason for the violation:

- The reason for the violation was described in LER 98-09 as follows: "The preparer and the reviewers of the safety evaluation failed to recognize that the limiting single failure was not assumed in the gas entrainment analysis and that such an assumption was required if the MU/HPl 6Y

[ Makeup and Purification /High Pressure Injection] System lineup were revised to operate with a common MU/HPI suction header." Therefore, the basis for the 50.59 evaluation documented in SE 000211-015 was incorrect.

Corrective steps that have been taken and the results achieved:

The condition cited in the violation was corrected on August 20,1998 when the Makeup Tank

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(MUT) operating limit to prevent gas entrainment was revised. The revised operating limit

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192(L98-20654

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restores the validity of the original basis for the determination in the safety evaluation that the j.

change did not involve an unreviewed safety question (USQ).

Correptive steos that will be taken to avoid further violations:

1. A permanent resolution, to either adopt the temporary change or to revise the MUT

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pressure / level limits analysis as appropriate along with establishing procedure cc.1.trols to address the failure of a Borated Water Storage Tank (BWST) suction valve (MU-V-14A or MU-V14B), will be determined and implemented by December 20,1998.

2. A review of the configuration control process, including the calculation process, i will be conducted to determine ifimprovements are necessary to ensure

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appropriate and consistent application of the single failure criteria. This review will be completed by July 1999 and any resulting recommendations will be implemented by December 1999.

3. The guidance for the preparation of safety evaluations will be reviewed to determine if enhancements are necessary to improve quality and consistency. This review will be completed by July 1999 and any resulting reconunendations will be implemented by December 1999.

4. Written guidance will be provided for all Responsible Technical Reviewers

!- (RTRs) and Independent Safety Reviewers (ISRs) by December 1,1998 to heighten their awareness of the need to ensure that the most limiting single failure has been identified.

The date when full comoliance will be achieved:

Plant operation and design were in full compliance with the requirements of 10CFR50.59 on , ;

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l August 20,1998 when the basis for the 50.59 evaluation (SE 000211-015) was restored.

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