ML19241A996
| ML19241A996 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/08/1979 |
| From: | Herbein J Metropolitan Edison Co |
| To: | Robert Carlson NRC Office of Inspection & Enforcement (IE Region I) |
| Shared Package | |
| ML19241A994 | List: |
| References | |
| GQL 211, GQL-0211, NUDOCS 7907110521 | |
| Download: ML19241A996 (4) | |
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POST OFFICE BOX 542 READING, PENNSYLVANI A 19603 TELEPHONE 215 - 929-3601 February 8, 1979 GQL 0211 Mr. Robert T. Carlson, Chief U.
S. Nuclear Regulatory Commission Reactor Construction & Engineering Support Branch 631 Park Avenue King of Prussia; Pennsylvania 19406
Dear Sir:
Three Mile Island Nuclear Station Units 1 & 2 (TMI-l & TMI-2)
Operating License Nos. DPR-50 and DPR-73 Docket Nos. 50-289 and 50-320 Inspection Reports Nos. 78-25 & 78-38 This letter and the attachment are in response to your inspection findings letter of January 17, 1979 concerning Mr. L. Gage's inspection of TMI-l and TMI-2.
Results indicated one apparent defi.ciency and two apparent infractions for TMI-2.
Sincerely, J. G, Herbein Vice President-Generation JGR:LW: tas Attachment 9
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Metropolitan Edison Company Three Mile Island Nuclear Station License Nos. DPR-50/DPR-73 Docket Nos. 50-289/50-320 Inspection Nos. 78-25 and 78-38 Based on the results of an NRC inspection on December 12-15, 1978, it appears that certain of your activities were not conducted in full compliance with NRC regulations at.d the conditions of your license as indicated below.
Items A and C are infractions and Item B is a deficiency.
Infraction A Appendix A c t' e Licerse. ir paragrcph 6.8.1, states: " Written procedures
' ed, ' c,.. ment; and main tained... "
shall ne est-Licensee Pracadare /P 103,, in paragr
. 6.3 states: "Should it become necessary o exe_ei -ha 11mits (of transient combustible material) for brief periods, tl.e cogr tzaot de.partment head...must qualitatively evaluate any additional pot cr temporary fire protection measures which must be taken in the erec...while the limit...is exceeded, the area must be manned, or a fire watc_t pacrol...at least once per hour be established."
Contrary to the above, empty cardboard boxes were stored in the cable spreading room, recording paperwas stacked on temporary tables there, and a hot soldering iron was plugged into an outlet near the recording paper; however, the area was not manned nor had a fire watch patrol been established.
Response to Infraction A Immediate corrective action taken in regards to Infraction A was as follows:
1.
the soldering iron ns unplugged and 2.
the cardboard boxes were removed from the Cable Spreading Room.
These actions removed the potential fire hazard and placed us within the allowable limit for combustibles in the evea.
Corrective action to avoid further items of noncompliance has been taken.
All I&C Department personnel were advised that transient combustible materials in excess of the allowable amount for a specific area shall not be left unattended without the appropriate fire watch being established. Also, hot soldering irons shall not be left unattended. These actions are consistent with AP 1034.
Full compliance was achieved on January 30, 1979.
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Deficiency B Appendix A to the License, in paragraph 4.7.10.1.2(a)2, states: "Each fire pump diesel engine shall be demonstrated operable at least once per 31 days:
...The diesel starts from ambient conditions and operates for at least 20 minu t es. "
License Procedure AP-1010, in paragraph 6.6.1, states : "A retest is required when initial test results fail to meet the acceptance criteria or when the test could not be entirely performed.
Retest results will be... evaluated, along with the original data sheets, by the Test Coordinator..."
Contrary to the above, a retest of steps 3.a, b, and c of Surveillance Report 3303-M1, dated September 18, 1978, was not performed when the initial test f ailed, and the test coordinator did not sign the front page of the surveillance report to indicate that he had evaluated the test results.
Response to Deficiency B The diesel did not start in the Manual I position.
However, it did start in Manual 2, where upon the operator performed the remainder of the surveillance test.
Since T.S. 4.7.10.J 2(a)2 requires only that the diesel be started, not that both starr circuits ue operable, the test met acceptance criteria.
A test which meets acceptance criteria, even though one or more temporary malfunctions exist, requires no retest data or evaluation per AP 1010.
The inspector may have misunderstood the exception which existed (failure of the Manual 1 start circuit) for a deficiency.
A deficiency results from obtained data or conditions which f ail to meet acceptance critcria (AP 1010,3.2.4.2).
The job ticket written to correct a deficiency must contain re test data, or such data must appear in the surveillance file. The GMS Coordinator must evaluate the retest data to make sure it meets acceptance criteria.
This requirement exists only when original data "...f ail (s) to meet the acceptance criteria or when the test could not be entirely performed" (AP 1010, 3.3.1).
Since original data met acceptance criteria, and since the test was entirely performed, no deficiency existed which would require retest and evaluation.
An " exception" includes any irregularity or partial nonperformance of a surveillance test which exists yet still allows the test to meet acceptance criteria.
This occurred during the 3303-MI performance in question.
Although one start circuit failed, the test yielded data which met acceptance criteria for the surveillance, since T.S. 4.7.10.1.2(a12 requires only that the diesel start.
"The inspector noted that the September 18, 1978 issue of surveillance report 3303-M1 indicated a f ailure to completed steps 3.a, b, and c (the Manual I start function test for the fire pump diesel engine). Work Pequest No. 25237 was issued, which indicated that the diesel engine was repaired.
However, it did not indicate that steps 3.a, b, and c were then satisfactorily perfor=ed".
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Although a retest was not required, Work Request No. 25237, Step 13, " Post Maintenance Testing and Acceptance Criteria" states that the " diesel started in manual." The reviewing foreman checked "yes" under " Retest Met Acceptance Criteria".
Steps 3.a b, and e of 3033-M1 require a manual start, a period of idling and a manual shut down. To satisfy acceptance -riteria, the operator initials that these events occurred. These steps require no number data such as idle time or cranking RPM.
Therefore, the statement that the " diesel starts in manual" satisfies acceptance criteria for a retest.
"The inspector noted that neither the shif t supervisor nor the test coordinator had signed the trent page of the September 18 report to indicate that they had evaluated the test restult. He thereupon rechecked the surveillance report file, but did not find any retest report for the month of September."
No space occurs on any data sheet which may appropriately be signed by eithe' the Shift Supervisor or the Test Coordinator.
The " front page of the... report" exists solely as a computer entry device and does not constitute part of the surveillance test data.
Signatures on this page are superfluous, since they appear on the actual data sheets.
"The inspector considered this contrary to the licensee's procedure AP-1010,
" Technical Specification Surveillance Program," (Rev. 12) which states, in paragraph 6.6.1: "A retest is required when initial test results fail to meet the acceptance criteria or when the test could not be entirely performed.
Retest results will be. recorded on another set of data sheets or in the retest section of a %'ork Requeet.
Retest results will be... evaluated, along with the original data sheets, by the Test Coordinator to determine that the surveillance requirement has been satisfied."
AP-1010 requires neither retest nor evaluation of retest data for exceptions.
Therefore, we do not feel that Deficiency B is valid.
Infraction C
, to the License, in paragraph G.9, states: "By July 31, 1978:
Provide additional fixed sealed-beam emergency lights to f acilitate emergency operation at remote shutdown panels and f acilities...".
Contrary to the above, additional emergency lights had not been installed in the cable-spreading room to facilitate emergency operation of the remote shutdown panel.
Response to Infraction C In response to the above apparent infraction, Change Modification 2-0332 was generated to correct the location of the additional emergency lighting to an appropriate location that would provide lighting for the remote shut-down panels. This work was performed via Work Request No. C-0747.
Full compliance was achieved on February 2,1979.
No further action is considered necessary.
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