ML19345E956
| ML19345E956 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/13/1980 |
| From: | Hovey G METROPOLITAN EDISON CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19345E953 | List: |
| References | |
| TLL-589, NUDOCS 8102060472 | |
| Download: ML19345E956 (4) | |
Text
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Metropolitan Edison Company Post (Mfice Box 480 g
Middletown, Pennsylvania 17057 717 9444041 Writer's Direct Dial h umber November 13, 1980 1
589 Office of Inspection and Enforcement Attn:
Mr. Boyce H. Grier, Director Region I U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Sir:
Three idle Island Nuclear Station, Unit 2 (TMI-2)
Operating Leiense No. DPR-73 Docket No. 50-320 Inspection Report 50-320/80-11 Tais is in response to the subject Inspection Report issued on October 7,1980.
In a letter dated November 3, 1980, (TLL 572) we informed you that the response would not be ready for submittal until November 11, 1980.
Subsequent to that letter, Mr. S. D. Chaplin, of our Licensing Departatnt, informed Mr. R. J. Conte, Senior Resident Inspector, Unit 2, TMI Prograa Office, on November 12, 1980, that the response was not yet finalized but would be submitted on November 13, 1980.
The items addressed in item A and B occurred during the preparation for and performance of the purge.
The conduct of the purge process was done in an expeditious manner with the specific evolutions in many instances being unique to this period.
These may have been contributing factors in that the additional assurances associated with normal operations may not have been fully exercised during this period. Additionally, these occurrences occurred during the early stages of the purge evolution and were quickly remedied.
In no case was there any threat to the health and safety of the public.
ITEM A
-- On June 25, 1980, during the implementation of S0P R-2-80-40, manual isolation valves (FS-V422B, 423B, and 424B) for the reactor building ventilation and hydrogen control exhaust filter fire protection system were in the shut position. This was contrary to SOP R-2-80-40, pre-requisite 4.25 which required that these valves be open by reference to the Fire Protection System Operating Procedure (2104-6.1).
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During the performance of the prerequisite checks in the above-mentioned SOP, the referenced deluge valves were determined to be not in their procedurally required position.
Since this was the performance of a " DRY RUN" procedure, one in which no functional operation of either the containment isolation valves or the system fans was to be performed, the correction of the discrepancy was not necessary to cor lete the dry run exercise nor would it have any impact on the intent, performance of, or completion of the remainder of the SOP.
The discrepancy was noted, its impact reviewed, and based on the above, the SOP was then completed.
l 810 2 0 6 0 T4 Metrooo'itan ee: son company,s a Member of the General Public Unlities Syste,m
... B.,H. Grist TLL 589 i
By means of a Temporary Change Notice (TCN) the referenced Fire Protection System Operating Procedure was amended to change the position of the deluge isolation valves from normally open to normally closed. The purpose of the change was to avoid an inadvertant actuation of the deluge system in the filter assemblies of the air handling systems being utilized during the purge. This change did not ef fect any portion of the Fire Protection System other than to override the automatic deluge initiation. The TCN was issued June 27, 1980, before commencement of the purge on June 28, 1980.
-- On July 1,1980, for approximately 20 minutes, AH-V3A, Containment Isolation Valve for the Modified Hydrogen Control (MHC) System, was left open on a " temporary shutdown" of the system. This was contrary to OP 2104-4.82, paragraph 5.4.2, which required that this valve be shut on a " temporary shutdown" of the MHC System.
Valve AH-V3A was inadvertantly left open by the operator conducting the temporary shutdown of the. purge. Apparently,'the operator did not follow the procedure which resulted in the valve being left open. The valve was closed after the valve position was brought to the attention of the Supervisor of Operations.
The operator involved was counseled on the need to follow the procedures. This situation did not result in a threat to the health and safety of the public in that two valves in series with and between AH-V3A and the stack (AH-V25 and AH-V26) were closed and the Reactor Building was at a negative pressure.
On July 3, 1980, for approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, AH-V3B, Containment Isolation Valve for Modified Hydrogen Control (MHC) System was left shut on the startup cf the MHC System. This was contrary to OP 2104-4.82, paragraph 5.2.10 which required that this valve be open to provide a return path for reactor building makeup air. This resulted in an unscheduled shutdown of the system due to reactor building pressure reaching a procedural-low limit.
This infraction was due to a combination of personnel error and a procedural control inadequacy.
Four (4) TCN's were issued to modify the referenced procedure, one of which-required that AH-V3B remain open. This TCN, No. 2-80-231, was the result of an effort to avoid frequent cycling of this inside containment valve to avoid the possible development of any problems which could render the valve inoper-able. At the time of the issuance of this TCN, a copy of the cce rolled procedure was being used in the field to conduct the purge. This TCN was not issued to the field copy of the procedure. As a result, the~ operator who placed the purge in the Temporary Shutdown Mode was not aware of this TCN which required AH-V3B to be open and, therefore, closed the valve as the unammended procedure which he held instructed him to do.
The operator who restarted the purge was aware that this TCN had been issued and, therefore, believing the valve was open, did not check the valve posi-tion as required in the startup procedure. This led to a system startup with AH-V3B closed, eliminating the source of makeup air and resulting in the unscheduled shutdown.
The corrective actions taken to avoid any reoccurrence of these problems include:
1.
All TCN's to the reference procedure were incorporated into a Revision to the procedure.
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B..H. Crist TLL 589 2.
A RB Purge Turnover sheet delineating status of various purge conditions and valve positions was instituted.
3.
A " Procedure In Use Logbook" has been instituted to insure revisions and changes are incorporated into procedures in use in the field at the time the revision / change is incorporated into the controlled copy of the procedure.
The licensee believes that the corrective actions taken for the conditions discussed in item A are sufficient and that the licensee is now in full compliance with the refcrenced procedures.
ITEM B Contrary to Station Administrative Procedure 1026, on June 29, 1980, the licesee worked on the Modified Hydrogen Control System exhaust fan while it was exhausting the raactor building atmosphere and no " Work Request" form was completed. During the evolution the indi-vidual caused the f an to trip (automatic shutdown).
Work was performed by a contractor on June 29, 1980, on the Modified Hydrogen Control System exhaust fan without a Work Request. The contractor has been formally reprimanded with respect to this inci-dent and informed of the necessity to perform tasks within the established administrative controls.
As a result of this incident, a memo will be issued by November 17, 1980, to all contractors whose work could have an impact on plant conditions, emphasizing the need to work within the established admini-strative guidelines.
The licensee believes that these corrective actions are sufficient to avoid further items of nonco=pliance of this type.
ITEM C
-- Contrary to-the Unit 2 Health Physics Procedure 1682, Revision 4,
" Control of Contaminated Tools, Equipment and Materials", between June 20 and 26, 1980, several items which had fixed or removable contcmination in excesu of the limits of Health Physics Procedure 1682 were given unconditional release to clean areas from a Unit 2 control point.
Maximum removable contamination' exceeded 10,000 dpm/
100 cm and maximum radiation level was 10 mrad /hr on one piece of 2
pipe.
Upon identification, the licensee placed all contaminated items release to noncontaminated areas under immediate control as radioactive material.
An investigation to determine the cause of the situation was conducted.
The investigation resulted in the identification of two apparent causes; they are:
1)
Inconsistency by H.P. Techs in the procedure and criteria used for the release of materials from controlled areas.
- 2) Poorly marked areas used for holding released material caused confusion at the release noint as to what material was authorized for release.
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B.,H. Griar TLL 589 Subsequent to the determination of these apparent causes, all TMI-2 Radiological Technicians were briefed on this incident and release survey techniques / requirements. In addition, a release survey form was developed for the purpose of documenting survey (s) taken on all material exiting radiological controlled area exit stations. The use of this form was directed by a memo of July 8,1980, by the Radiological Control Field Operations Manager.
The implementation of this practice has eliminated any possible source of confusion resulting from the previous handling practices. The licensee believes that these actions are sufficient to avoid further items of nonco=pliance in this area.
ITEM E Contr ary to 10 CFR 19(a)(4), (d), and (e), as of June 30, 1980, none of the orders issued pursuant to Subpart B of Part 2 (10 CFR 2) since July 20, 1979, were posted.
In addition, the Notices of Violation issued by the Office of Inspection and Enforcement (Region I), dated May 28, 1980, and by the Office of Inspection and Enforcement, dated October 25, 1979, were not posted in a sufficient number of places, that is, one (dated May 28, 1980) was posted only on a bulletin board in the Unit 2 Control Room and the other (dated October 25,1979), was not posted in Unit 2.
These, atices of Violation involve certain uncorrected radiological working conditions. The Unit 2 control room bulletin board is not a normal access to radiological areas such as the auxiliary building.
To eliminate the situation where posting of 10 CFR 19 required matarial is inconsistent, the licensee's responsibility to post these materials has been brought to the attention of the applicable departments within this organiza-Specifically, the onsite Licensing Department has been tasked with tion.
identifying the required subject items for posting by the Administrative Controls Department.
In addition, the items referenced in this Inspection Report as not having been posted, will be posted in controlled locations by December 31, 1980.
With regard to posting of items in 10 CFR 2, Subpart B, Section 2.204, it is the licensee's opinion and intent that those orders relevant to changes in the proposed Technical Specifications, Appendix A, of the license as l
issued by the order of February 13, 1980, are included within the scope of 10 CFR 19.11(a)(2) due to the unique status of the Unit 2 Operating License and as such will be posted in accordance with the requirements of that section.
-The licensee believes that these actions are sufficient to ensure that further items of noncompliance in this area will be avoided.
Sincerely,
/
. K. Hovey Vice-President and '
GKH:SDC: dad Director, TMI-2 cc: Bernard J. Snyder John T. Collins
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