ML19262A352

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Responds to NRC 740621 Re Violations Noted in Insp Rept 50-289/74-25.Corrective Actions:Improperly Positioned Decay Heat Removal Sys Valves Repositioned & Procedures Reviewed & Revised
ML19262A352
Person / Time
Site: Crane Constellation icon.png
Issue date: 07/15/1974
From: Arnold R
METROPOLITAN EDISON CO.
To: Brunner E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19262A348 List:
References
GQL-0158, GQL-158, NUDOCS 7910260673
Download: ML19262A352 (3)


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METROPOLITAN EDISON COMPANY

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' OFFICE BOX 542 READING. PCfd4SYLVANI A 10G03 TELEPHONE 215 - 920 0C01 l

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July 15, 197h i'

CQL 0156 l

t Elden J. Brunner, Chief Reactor Cperations Branch Directcrate of Regulatory Oper.tions, Region 1 U. S. Atenic Energy Cennissio.

631 Park Avenue King of Prussia, Pennsylvania 19h06 i

Dear Mr. Brunner:

i Operating License Lo. DPR-50 Inspection No. 50-289/7h-25 This 1.etter and the attached enclosure are in response to your inspection report letter of June 21, 197h, concerning :'r. Spessard's June 3-6, 197h, inspection of Three Mile Island nuclear Station, Unit 1 and the findings thereof.

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C. Arnold Vice President RCA:D::G:lv Enclecure: Re: pence to Deceription of Apparent Violatiens 1483 154 1 9.1Oggg,..

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ENCLOSUPE Metropolitan Edicen Cc pany Three Mile Island nuclear Statien, Unit 1 Operating Licence No. EFR-50 Inspecticn No. 50-269/7L-25 Restense to Descrittien of Arrarent VicIatiens Apcarent Violaticn 1 1.

The FSAR Section lA, Oparating Quality Assurance Plan,Section VI, Document Centrol, states in part:

"...The Generation Divisicn doc-u=ent centrcl precedure further requires that each Manager and Station Superintendent provide in their procedures for measures:

...to ensure that approved changes be prc ptly transmitted for incorporation into documents; and to ensure that obsolete or superseded docu=ents are eliminated frc= the syste:

'd not used..."

Contrary to the above:

a.

On June h, 197L, the Makeup and Purification Syste= vas being lined up during preparations for initial criticality with the Control Rec '4crking Ccpy of OP 110h-2 Revision 1, altheuch the Control Rec: File Copy of 0F 110L-2 was Revisicn 2.

The effective revisien of this procedure va, Bevision 3 which had been distributed on May 2h, 197L.

b.

On May 30, 197h, the Decay Heat Re=cval Syste= vas lined up during preparation: for initial criticality in accordance with CP 11CL h.

The valves were pocitioned to the valve checklist, Enclosure I, Revision The correct revisien of Enclosure I was Revisicn 2, s.

dated Apr.

27, 197L.

In both cf thesa 'n tances, the differences between the superseded and revised precedures 2acluded the folleving:

1) Valves being added tc the list of things to be checked; 2) Valve positiens being changed frc=

open to cloced 2nd vice versa; and 3) 7alve status being changed fr:=

" closed" to " locked clcsed", etc.

Response

a.

A conpariccn cf current and previcus editicns of procedures used to alicn all cafety related systems during preparations fer initial criticali:7 was made and:

1.

No un:2fe ecnditions were found te exist as a recult of having used several cutdated editions, sni 2.

irproporly positioned valves were repositicned in acccrdance 1485 153" vitt the current checklists.

b.

To avoid tuture violations of this tyTc:

1.

a complete audit of all precedure filec vac conducted and included (a) replacing outdated precedure: vith current editionc,

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A (b) destroying spare copies of valve checklists, 2.

It has been decided to conduct future audits of this same type on a periodic basis, and 3.

a memo has been written to (a) define those individuals responsible for maintaining up-to-date procedure files and (b) reiterate to operations personnel the importance of assuring they use only current precedures.

c.

All the above corrective act$o.s were also reported in abncrnal occurrence report A0 50-209/7k-7, dated June lL, 197k; and as noted therein full ecepliance was achieved by that date.

Apptrent Violation 2 The FSAR Section lA, Cperating Quality Assurance Plan,Section VI, Document Control states in part:

"...The Superintendent of the TMI Station Unit 1 vill ensure that no changes are made to site instructions, procedures, and drawings unless such changes are apprcved by the appropriate approving organizaticn..."

Contrary to the above, the Waste Gas Disposal Syste= vas lined up during preparations fer initial criticality in accordance with CP 11Ch-27. The Control Rect Working Copy of this procedure had changes to valve, level indicator and electrical panel designators en Pages 5 and 6 without any approval ind.tcated.

Response

a.

I=nediate investigatien of the differences between the Control Roc =

Working Copy of OP 110L-27 and the current ecpy resulted in the conclusien that no unsafe ecnditions exisced.

Further investigati:n into v'ry nc approving signature appeared en the Contrcl R:c Jorking Ccpy revealed that a Temporary Change :;otice (TC:i) had been requested, but that it had not yet been apprcved. The requested TC:! vas then reviewed and approved.

b.

To avoid future viciatiens of this type all shift supervisors and reacter operators were instructed in the proper method for taking changes to procedures.

c.

Full ccrpliance has been achieved.

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