ML19220B418
| ML19220B418 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/20/1978 |
| From: | Herbein J Metropolitan Edison Co |
| To: | Grier B NRC Office of Inspection & Enforcement (IE Region I) |
| Shared Package | |
| ML19220B417 | List: |
| References | |
| GQL 1108, GQL-1108, NUDOCS 7904260004 | |
| Download: ML19220B418 (4) | |
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METROPOLITAN EDISON COMPANY sussicisar or centan pueuc ununes cosponArion POST OFFICE BOX 542 READING. PENNSYLVANI A 19603 TELEPHONE 215 - 9 3 3601 June 20, 1978 GQL 1108 M. 3. H. Crier, Director Office of Inspection & Enforce =ent Region 1 U. S. Nuclear Regulatcry C 4 ssion 631 Park Avenue King of ? ussia, Pennsylvania 19h06
Dear Sir:
Sree Mile Island Nuclear Statier Unit 2 ('DiI-2)
Operat ug License No. DFR-73 Docket No. 50-320 Inspection Report No.
78-20 This letter is in respense to the subject inspecticu report resulting frc=
Mr. Higgins inspection of May 10-12, 1978, and the findings thereef. 3elev are the responses to the infractions referenced in the subject inspection.
Infractions A.
Technical Specification h.6.1.la states in part, that. "Pr mary i
CON'EENT I.T~EGRITY shall be de=custrated:
a.
At least once per 31 days by verifying that:
1.
2.
All equipment hatches are closed and sealed."
Centra.ry to the above, the licensee did not verify that the equipnent hatch was closed and sealed frcs February 9,1978 to May 12,1978.
3.
Technical Specification h.6.1.3.a states, that, "Each centainment air lock shall be de=enstrated CPEEABLE:
a.
"After ich opening, except when the air leek is being used for
- rltiple entries, then at least cnce per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, by veriP/2g 4
,< 9.01 La seal leakage by pressure decay when the volune between the icor seals is pressuriced to > 10 psig, for at least 15 ninutes.
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June 20, 1978 2-Mr. 3. H Grier, Directer G;L nC8 Centrary to the above, when the air lock vas being used for =ultiple entries, the seal leakage vas verified < 0.01 La by pressure decay cn 22, 1978 with the volu=e act pressurized March 19, April 7 and April A pres-to > 10 psig and using a test interval cf less than 15 =inutes.
frc= 10 psig to O psig with an acceptance criteria of at sure decay test least ten seconds was used.
" Written procedures Technical Specificatien 6.8.1 states in part, that C.
shall be established, i=ple=ented and maintained..."
Surveillance Procedure (SP) 2311-5, "Centainment Integrity" Rev.1, was issued en February 2h,1978 and Te=porary Change 'Totice (TC'7) 1.
to this precedure was issued on March n,1978.
2-78-292 AP 1001 " Document Centrol", Rev.13, datei March 30, 1978, step 3.8.5.5, Surveinance Precedures, states in paragraph (b) that, 2.
""he docu=entaticn specified must be filled in accurately and cc=pletely by the individual perfer=ing the surveillance..."
2-78-292, Appendix "B", Step 3 SP 23n -5, Rev. 1 vith TCN that, "The air lock used for entry was leak states in part, rate checked by pressurizing both at=cspheric door inner seals ares...and veriff ng pressure did not decrease to O iThe step then has fcur labelled blanks psig in < 10 seconds."
fcr the four air lock decre with the captien "Ti=e to Decrease to O psig."
Centrary to the above:
SP 23 n -5 was performed en March 13, March 18, March 22, March 26 1.
and April 13, 1978 without utilizing TCN 2-78-292; and, SP 23n -5 was perfer=ed en March 29, April 10, April 16 ando 2.
April 18, 1978 vithout recorM,g the Ti=e to Decrease to psig for any of the fcur air lock doors.
"?rocedures for personnel Technical Specification 6.n states in part, that, radiatica protection shall be prepared...=aintained and adhered to for all D.
operations involving persennel radiatien exposure.
Health Physics Procedure 1612, " Monitoring for Persennel Contamination",
22,1977, Step 5 3.2 states, that, "An personnel Rev. 5, dated September leaving a Centro n ed Area shall =cnitor the=selves and all hand-carried ite=s before entering a clean ares."
11, 1178, en Centrary to the above at approxi=ately 12:15' p.=.
cn Mayindividual left the Unit 2 Reacter Building Centro 11ed 1e clean drea
=ent hatch door with an air 3ettle and hoses and entered t:
outside without =critering hi=nelf or his hand-car-ied itens.
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b!r.3.H.Grier, Directer
~ June 20, 1978 GQL 1108 Corrective A
+4--e ma>=n A.
In a =ajor revision to the =cnthly contai=ent integrity verificatien precedure in February 1978, the verification that "All Hatches are close:i
& Sealed" was overlooked and c=itted frc= the checklist.
'"his ad=inistra-tive error was corrected by 005 i=e:iiately upon disecvery.
Scugh not prcperly doc =ented, the require =en", of k.6.1.1.a.2 was satisfied during each =cnthly centai=ent integrity verificatica since the equip =ent batch has not been re=oved since receipt of our cperating 11-cense en Tab. 8, 1978.
3.
'n' hen conve:-te:i to a timed pressure decay, the acceptance criteria for dcor seal leakage of < 0.01 La yields a 10 PSIG pressure drop in < 10 seconds.
D e air icek =a.nufacturer was consulted to determine the =axi='=1 allevable test pressura between the door seals which he specified as 10-12 PSIG. Thus the door seal test procedure vns written to pressuri::e the area between the decr seals to 10 PSIG for a period of 15 =inutes, re=oving the pressure source and observing that the pressure did not decay to O PSIG in less than 10 sacends.
Met-Ed centends that this precedure satisfied the verding of the Surveillance Requirement k.6.1.3.a, however, at 3RC I & E's request, a tech spee change request has been initiated to allev performance of this test using a rotc=eter type of ficv=eter in a =anner sf Mlar to local leak rate testing on individual centai=ent isolation valves. Precedures have been changed to utili'.e this method at the request of I & E since it =cre fally satisfies the intent of the Surveillance Requirement than the literal requirenent to perform a pres-sure drop test.
C.
Perfor=ance of a procedure for which a TCN is applicable without incorpcrating the te=perary change in affected steps, vas an oversight en the part of the operator. To avoid future occurreces of si-17 ar incidents, a change to AP1001 has been incorporated to require that each step affected by a te=pers: r change notice be flagged as such in the bod e of the centrol rec = file and verking copy of the procedure in addition o attaching the TCN to the top of the precedure.
D.
All operators have een re-tratructed in the requirements of EPP 1612 in general and briefed cn the prcper method of performing Surveillance Proceciure 2311-5 including the preper pruc-d"% n r gaining access to air leck door s'eals.
Cor ective Sters Taken to o revent aav Future Recur ence The corrective actions stated above are sufficient to prevent any fature rc
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Mr. 3. H. Grier, Directer h-June 20, 1978 GQL 11C8 recurrence of these infractions and therefore, no additicnel ccrrective steps are necessary.
Sincerely,
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J. G. Herbein Vice President-Generation JGH:JFS:cJg i
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