ML19220B729

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Responds to NRC Re Violations Noted in IE Insp Rept 50-320/77-32.Corrective Actions:Personnel Reviewed Infractions,Hot Functional Test Coordinator to Submit Repts
ML19220B729
Person / Time
Site: Crane 
Issue date: 10/12/1977
From: Herbein J
Metropolitan Edison Co
To: Grier B
NRC Office of Inspection & Enforcement (IE Region I)
Shared Package
ML19220B716 List:
References
GQL1381, NUDOCS 7904270265
Download: ML19220B729 (2)


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POST OFFICt BOX 542 READING, PE NNSY LV ANI A 19003

< ONE 215 - 929 3001 October 12, 19?T G^J.1381 Mr. B. H. Grier, Directar U. S. Nuclear Ecgulatory Cc=nission Office of Inspection and Enforce =ent Region I 631 Park Avenue King of Prussia, Pennsylvania 19406

Dear Sir:

Three Mile Island Nuclear Station Unit 2 (TMI-2)

License No. CPPR-66 Docket No. 50-320 Inspectico Report 77-32 The subject inspection report rerelting from Mr. P. Kellogg's inspection of August 8-19, 1977, contains an infraction concerning perfor=ance of Test Fro-i cedures at Three Mile Island Nuclear Station Unit 2.

This letter constitutes the written response to this infraction.

_ INFRACTION 10CFR50 Appendix B, Criterion II, Test Control, states in part, "...all testing required to de=custrate structures syste=a and co=ponents vill perform satis-factor 117 in service in identified and perfor=ed with written test procedures which incorporate the reptraments and acceptance limits..."

The licensee'.2 Test Manual, Test Instruction T1-9, Conduct of Test, section 3.3.2.6 states that, "... changes to test procedures are r=4 by making an exception to it or by initiating a Test Change Notice (TCh, Contrary to the above, duri-g the period from August 8-19, while performing Hot Functional Testing, the lie ensee failed to initiate test exceptions or TCN's for the follaving tests:

- TP 600/5 Chemical A.1dition and Sa=oling Operational Test. The licensee failed to initiate an exception or TCN vhen the pre-requisite was not co=pleted prior to perfor=ance of paragraph 9.7, Lithiun Hydroxide Addition, and paragraph 9.8, the Verification of ESF Valve test sequence, as required by Hot Functional Test Control procedure TP 600/28; and,

- TP 600/28 HFI Control Procedure. The licensee failed to initiate an exception or TCN for a change made to the chc=ictry requirments of the Rer,ctor Coolant System (RCS) involving increasing the RCS Te=perature to greater than 2500F vith the Lithium requirements out of specification.

The specification required LiCH E 0.2 ppm, while the RCS analysis recorded 0.09 ppm LiCH.

79042702Gr M'340

Mr. B. H. Crier, Director October 12, 1977 CQL 1381 RESPONSE TO INFRACTION TP 600/5 Chenical Addition and Sa=pling Operational Test.

A.

During perfor=ance cf TP 600/28 the sequence required addition of chemical 1

to the Reactor Coolant System by use of IP 600/5. The Shift Test Engineer (STE) added the che=ical in accordance with TP 600/5 Section 9.7, but failed to write an exception to TP 600/8 Section 4.1.1 which stated that TP 210/12

" Nuclear Che=1 cal Adcition Syste= Functional Test" was a pre-requielte for che=ical injection.

B During perfor=ance of TP 600/28 the STE perfor=ed Section 9.8 of TP 600/5 at a different pressure /te=perature plateau thaa required by IP 600/28.

Although there was not a technical require =ent for Section 9.8 to be per-for=ed at any particular te=perature plateau, the STE failed to enter this as an exception to docu=ent when the test was done.

IP 600/28 Ect Functional Test (HFT) Control Procedure Prior to the initial heatup of the unit, it was deter =ined that the Lithium was 0.09 ppm with a requirement to be >0.2 pp= and the unit Che=1stry Department was requested to calculate the required amount of Lithiu= to be added to :be RCS.

Af ter the Che=istry Department supplied the correct amount of Lithium, it sas added to the che=1 cal addition tank and injection into the RCS was started. At this point, the STE began the heat up from less than 2500F to the 350 F plateau.

The Lithium was gr, eater than 0.2 ppm within sLx hours, but the STE failed to docu=ent it as an exception.

In order to insure that the involved test personnel docu=ent exceptions and TCN's properly, they have all been reinstructed on Test Instruction #9, Conduct of Test, and they have all reviewed this infraction. The reinstruction and review were docu=ented in the Test Log Book prior to-october 10, 1977 with each individua1' acknowledging it by initialling the log.

In addition, by =e=o TMI-II-5970, the Test Superintendent has tasked the HFT Coordinator with a

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daily review of the HFT procedures and a weekly status report to insure the test instructions are being followed.

Sincer ely, G. Herbein Vice President JCHiJRS:dkf cc:

Dr. Ernst Volgenau,11 rector Of fice of Inspection and Enforcement

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U. S. Nuclear Regula :ory Co==1ssion Washington, D. C.

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