ML19256D246
| ML19256D246 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/06/1977 |
| From: | Herbein J METROPOLITAN EDISON CO. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19256D243 | List: |
| References | |
| GQL-1369, NUDOCS 7910170758 | |
| Download: ML19256D246 (3) | |
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l POST OFFICE BOX 542 READING. PENNSYLVANI A 19603 TELEPHONE 215 - 929-3601 October 6, 1977 GQL 1369 Mr. Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Brancii U. S. Nuclear Regulatory Co-4 ssion 631 Park Arenue King of Prussia, Pennsylvania 19406
Dear Mr. Brunner:
Docket No. 50-289 Operating License No. DPR-50 Three Mile Island Nuclear Station, Unit 1 Inspection Report No. 77-24 This letter and the attachment are in response to your inspection letter 3 of Septe=ber 19, 1977, concerning Mr. J. Higgins inspection of TMI-l
and the resultant findings of three (3) apparent infractions.
Si
- erely, a
. G. Herbein Vice President JGH:DGM:dkf Attach =ent 1450 074 T
075 791 017
Metropoli,tanEdisonCompany Three Mile Isi'and Nuclear Station Unit 1 (TMI-1)
Decket No. 50-289 h-License No. DPR-50 Inspection No. 77-24 RESPONSE TO DESCRIPTION OF APPARENT VIOLATION INFRACTICN A 10 CFR 50.54 states in part, that "Whether stated therein or not, the following shall be deemed conditions in every license issued:
....(c) Primary reactor containments for water cooled power reactors shall be subject to the requirements set forth in Appendix J".
Apperdix J to 10 CFR 50, paragraph III.A.3(c) states:
" Test leakage rates shall be calculated using absolute values corrected for instrument error.
Contrary to the above temperatures, pressures and vapor pressures used to calculate leakage rates for the April,1977, Type A test were not corrected for instrument error.
RESPONSE TO INFRACTION A The leakage rate for the 1977 Integrated Leak Rate Test will be recalculated using g data corrected for instrument error.
The recalculation will be complete by 10/31/77.
The procedure will be revised as necessary to comply with 10CFR50 Appendix J with regard to correction for instrument error.
The procedure revision will be completed by 1/10/78.
INFRACTION B Appendix B to 10 CFR 50, Criterion XIV states in part, that "... measures shall also be established for indicating the operating status of structures, systems and components of the nuclear power plant...to prevent inadvertent operation."
The Three Mile Island Operation Quality Assurance Plan, Revision 6, Section 19, states, in part, that "The Station Superintendent is responsible for the station procedures relating to the operational status of the entire station".
Contrary to the above, measures which were established did not prevent inadvertent operation, in that PP-V8 and PP-V64 designated as locked open on the locked valve list were found unlocked and shut on August 25, 1977, thus isolating manifolds A and H of the Penetration Pressurization System.
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i RESPONSE TO INFRACTION B PP-V-8 and PP-V-64 had been closed to perform maintenance on the respective
'q penetration pressurization manifolds.
Upon discovery that the valves had been mistakening left closed, they were immediately opened.
These valves are now locked open as required by the locked valve log.
To prevent further non-compliances of this nature, the Unit-1 Shift Supervisors / Foremen and CR0's will be reminded to document in the locked valve log any status change of any of the valves on the locked valve list.
Full compliance has been achieved.
INFRACTION C Technical Specification 6.8.1 states in part, that " Written procedures shall be established, implemented and maintained...".
Administrative Procedure 1011, Revision 12, dated June 6, 1977, paragraph 3.3.1 states, that "The locked valve list shall include the alpha numeric designation of the valve and its locked position and will be maintained in the Locked Valve Book."
The Locked Valve List included the following:
EG-V 1006 Locking device or collar installed EG-V 1007 Locking device or collar installed LR-V 1 Locked closed LR-V 6 Locked closed LR-V 49 Locked closed N
Contrary to the above, on August 25, 1977, the EG valves had no locking device or collar installed and the LR valves were not locked.
RESPONSE TO INFRACTION C LR-V-1, LR-V-6, LR-V-49 have had their handwheels chained and locked in the closed position to prevent further non-compliances of this nature.
The lock valve list will be verified by individual valve inspection after each refueling outage.
EG-V-1006 and EG-V-1007 are one-half inch tubing instrument isolation valves and because of their small size require a sheathing device over the entire valve instead of a stem collar device to insure uniform and adequate control per AP10ll.
This sheathing device has been installed and full compliance has been achieved.
1450 076