ML20003G399
| ML20003G399 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/26/1980 |
| From: | Hukill H METROPOLITAN EDISON CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20003G397 | List: |
| References | |
| TLL-587, NUDOCS 8104290312 | |
| Download: ML20003G399 (9) | |
Text
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Metropolitan Edison Company Post Office Box 480 Middletown, Pennsylvania 17057 V* iter's Direct Dial Nurnber November 26, 1980 TLL 587 Office of Inspection & Enforcement Attn:
B. H. Grier, Director Region I U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, FA 19406
Dear Sir:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Managenent Inspection Report 50-289/80-21 This letter is in response to Management Inspection Report 50-289/80-21 which contains nine apparent violations.
Attached please find our response.
Because of the confidential nature of the responses to Appendix B in, they should be withheld from public disclosure in accordance with 10 CFR 2.790(d).
Sincerely, J.
Director, TMI-1 HDH:LWH: hah Attachnent 1 2 (2.790(d) info.)
cc:
R. W. Reid J. T. Collina B. J. Snyder D. DiIanni H. Silver 81042003IA Metreochtan Ecson Comcanyjs a Memeer of tre General Putr UtMt:es System c
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b8 Attrchment 1 TLL.586 Management Inspection Report 50-289/80-21 ITEM A.
Technical Specification 6.5.1.6, "PORC-RESPONSIBILITIES" states, in part, "The Plant Operations Review Committee shall be responsible for...e.1) Review of reportable occurrences under Section 6.6 and any violations of these Technical Specifications or Operating License DPR-50, including a report... covering evaluation and recommendations to prevent recurrence, and 2) Review of violations of applicable federal statutes, codes, regulations and internal station procedures and instructions having nuclear safety significance."
Technical Specification 6.5.1.7, "PORC-AUTHORITY" states, in part,
'"The Plant Operations Review Committee shall...b.... at all times for 6.5.1.6(e), render determinations with regard to whether or not each item considered constitutes aa unreviewed safety question."
Contrary to the above:
1.
During the approximate period of the past twelve months for which records were examined, the Plant Operations Review Committee did not review and report their evaluation and recommendations for violations of Technical Specifications or review violations of internal station procedures having nuclear safety significance as reported in Quality Assurance audit reports.
The PORC did not review these audit reports or their findings.
Nearly every QA audit report examined contained findings which constituted violations of Technical Specifications and/or internal station procedures.
Examples of these findings are contained in QA audit reports 0-TMI-80-01 Finding 4, S-TMI-80-3 Findings 3 and 7, and S-TMI-80-08 Finding 11.
2.
During the approximate period of the past twelve =onths for which records were examined, the PORC did not render determinations with regard to whether or not items considered under Technical i
l Specification 6.5.1.6(e), including reportable occurrences, l
violations of Technical Specifications and violations of internal station procedures, constituted an unreviewed safety question.
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RESPONSE
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1.
The Quality Assurance Site Auditor has placed the PORC Chair =an on distribution for copies of all TMI-l QA Audit Reports and responses to these reports. Those reports which contain findings which constitute violations of Technical Specifications or internal station procedures having nuclear safety significance are reviewed by the PORC.
2.
The PORC now documents in the meeting minutes its determination with regard to whether or not items considered under Technical Specification 6.5.1.6(e) constitute an unreviewed safety question.
The above actions were instituted at meeting #80-70 on September 8, 1980.
Full co=pliance was achieved on that date and further ite=s of noncompliance are avoided by continuing the actions noted above.
.' s ITEM B.
Tcchnical Sp2cificerion 6.5.1, " Plant Op3rctions Revicw Committoa (PORC)," Section 6.5.1.5, " Quorum," states, "A quorum shall consist of fosr members, at least one of whom shall be either the Chairman or-Vice Chairman of the Committee. A quorum shall not take credit for more than one alternate member."
Contrary to the above, during PORC meetings 80-06 and 80-11, the quorum took credit for two alternate members.
RESPONSE It has been determined that a PORC quorum was in fact present for meeting 80-11 on March 12, 1980.
Although the meeting minutes did not list attendance by an additional principal member, this was apparently an oversight.
Review of documents signed at that meeting include the signature of the principal member, and his time sheet indicated
'four hours spent in PORC that day.
Since a full quorum was not present for meeting 80-06, the sole subject of that meeting was reviewed again on August 22, 1980 with a full PORC quorum. The subject was "MU-V73A/C Internals incident" which was reported as LER 80-03.
This later review confirmed the reportability of the subject event.
Full compliance was achieved on August 22, 1980.
A Plant Operations Review Committee Charter has been subsequently reviewed and approved and gives further guidance.on use of alternates to avoid further items of noncompliance.
The PORC Chairman or, in his absence, the Vice Chairman has been directed to insure a quorum is maintained at all times during PORC meetings.
fA.
ITEM C.
Technical Specification 6.5.2.A.2, " MET-ED CORPORATE TECHNICAL SUPPORT STAFF-RESPONSIBILITY," states, in part, "In its concern with the more detailed issues (rather than the broad issues) of nuclear safety, it shall be the responsibility of the Met-Ed Corporate Technical Support Staff to...d. Review of proposed changes to these Technical Specifications and Operating License DPR-50.
- f. Review of reportable occurrences, and violations of these Technical Specifications and Operating License DPR-50."
Contrary to the above, following the March 28, 1979, TMI-2 accident, the Met-Ed Corporate Technical Support Staff (MECTSS) was disbanded. Although many MECTSS responsibilities were subsequently performed by various organizational units of the GPU Service
. Corporation staff, the MECTSS review responsibilties had not been assumed in writing by any other organizational unit for:
(1) the review of proposed changes to the Technical Specifications and Operating License DPR-50, and (2) the review of reportable occurrences, other than those requiring twenty-four hour written notification to the NRC.
RESPONSE Following the accident at IMI-2 on March 28, 1979, the Met-Ed Corporate Technical Support Staff (MECTSS) focused its attention and resources to the problems associated with TMI-2.
On July 20, 1979 the TMI Generation Group.was formed and later altered on November 16, 1979.
During this time period a full time review Committee Chairman was assigned from the GPU Service Corporation office in Parsippany to conduct the necessary reviews for the MECTSS.
Because of the. overwhelming amount of documentation required by the GPUSC group to review, it was necessary that some of the reviews be postponed to a later date.
(These items mentioned above were both reviewed by PORC and GOR 3 in accordance with the TMI-l Tech-nical Specifications.)
On Septeuber 15, 1980 (Amendment $8) the Met-Ed Corporate Support Staff was officially replaced by the GPU Nuclear Group Corporate Staff (GPUNGCS). A new procedure will be 1.ssued by March 1, 1981 to delineate in writing the specific review responsibilities identified in TMI-l Technical Specification 6.5.2.A.2 that will be discharged by the TMI-1 Generation Review Committee.
In conjunction with this new procedure, a listing of other GPU Nuclear organizational units will be prepared to identify review responsibilities not specifically assigned to GRC.
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m ITEM D.
Technical Specification 6.5.2.3.1,." GENERAL OFFICE REVIEW BOARD (GORB)@ UNCTION," states, "In its concern with the broader issues (rather than the detailed issues) of nuclear safety, it shall be the primary responsibi).ity of the General Office Review Board to...a.
Foresee potentially significant nuclear and radiation safety problems and to recoinnend to the President of Met-Ed how they may be avoided.
b.
Periodically review the Generation Division audit program to assure that audits are being accomplished in accordance with requirements of Technical Specifications and ANSI 18.701972 Standard for Administrative Controls for Nuclear i
Power Plants."
Technical Specification 6.5.2.B.7, "CORB-REVIEW," states, in part, "The General Office Review Board shall review as is consistent with its responsibilities...c.
Proposed changes in and_ violations of these Technical Specifications or Operating License DPR-50."
Contrary to the above, during the period April 1, 1979, to June 30, 1980, the GORB did not review violations of Technical Specifications
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or Operating License DPR-50 as reported in Ouality Assurance audit l
reports.
The GORB OA Audit Subcommittee did review audit reports; however, their report on audits for the period April 1, 1979, to 1
June 30, 1979, was only a statistical summary of open audit findings.
It did not address the subject of any individual audit report or audit finding, which described violations of Technical Specifications.
PISPONSE The Met-Ed OA/OC Department has been reorganized and integrated into the GDUNC OA organization.
The OA organization is currently issuing a status of open audit findings on a monthly basis.
The GORB OA subcommittee is reviewing these status reports and the associated audits and issuing a summary report including violations of technical spccifications l
to the GORB periodically.
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Codn of Fad:rcl Regulctions, Titis 10, fcrt 50.59(b) sectea, in part,'?...The licensee shall furnish to the appropriate NRC Regional Office... annually...a report containing a brief description of such_ changes, tests, and experiments," f_made pursuant to 10 CFA 50.59(al/ " including a sununary of the safety evaluation of each."
~ Contrary to the above, as of August 1, 1980, changes made pursuant to 10 CFR 50.59(a) 'during calendar years 1978 and 1979 were not reported to the NRC. The last report of 10 CFR 50.59(a) changes was made on April 25, 1978, for changes made during 1977.
i RESPONSE On October 20, 1980 (TLL 472) the 10 CFR 50.59. Report for 1978 and 1979 was submitted to NRC Region I office. A Technical Functions
' procedure is being written to reflect the submission of this report at least annually.
The procedure is expected to be issued by February 1, 1981.
An action item has been written for the next report (1980) with a due date of March 1, 1981.
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ITEM F.
Technical Specification 3.18.4.1 states, "The CO2 system for the Cable Spreading Room shall be operable with a minimum level corresponding to 8500 lbm and a minimum pressure of 300 psig in the' associated storage tank (s)."
Technical Specification 3.18.4.2 states, in part, "With the CO2 system for the Cable Spreading Room inoperable:
- a. Establish a continuous fire watch with backup fire suppression equipment for the unprotected area within one hour."
These requirements are applicable at all times when the equipment in the area is required to be operable.
Contrary to the above, on December 31, 1979, while maintaining the plant in cold shutdown, the CO2 system for the Cable Spreading Room was noted by plant personnel to be below the 8500 lbm minimum level.
A fire watch was established within one hour but was not continuously maintained prior to restoring the system to an operable condition.
The fire watch was secured when PORC determined that no equipment in the Cable Spreading Room was required by the Technical Specifications to be operable, and that no fire protection was needed.
The PORC determination was in error, because equipment (instrument, control and power cables) in the Cable Spreading Room is required to be operable to monitor RCS pressure and temperature, within the limits of T.S. 3.1.2, and to maintain the plant in cold shutdown, although specific equipment operability requirements are not delineated by Technical Specifications.
RESPONSE The CO tank in the Relay Room normally contains a double charge.
2 Although the level was low, at no time was the inventory less than the 5000 lbm required by design to suppress a fire.
The PORC determinstion stipulated that waiver of the fire watch was contingent upon maintaining greater than 5000 lbm.
Technical Specification 3.1.2 on pressure and temperature implies the ability to measure and control those parameters. That capability did exist using equipment separate from the relay room. Pressure indication is available at the panel for Shutdown Outside the Control Room. A number of means exist for determining temperature, including local measurements of incore thermocouples and use of portable equipment such as pyrometers.
In addition, local indications of Decay Heat Closed System temperatures can be used to monitor for proper cooling.
Furthermore, the Decay Heat Removal System was operable and capable of controlling temperature; che Reactor Coolant System was on the Vent Header and therefore limited in pressure to less than any point on the T.S. curve; and the High Pressure Injection Pump breakers were racked out (this provides sufficient overpressurization protection as described in new T.S. 3.1.12).
Since the ability to suppress a fire in the relay room remained, and the ability to monitor and maintain the plant at cold shutdown using equipment remote from the relay room existed, no specific Technical Specification operability requirement was violated.
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PORC's reevaluation of this situation has demonstrated that the necessary specific operability requirements were met. However, to ensure that there is never any doubt as to whether the equipment in the area is in fact required to be operable, we will maintain a continuous fire watch in the Cable Spreading Room whenever the requirements of specification 3.18.4.1 are not met.
The PORC and membe.is of the Fire Protection Group will be so instructed.
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i APPENDIX B THIS PAGE CONTAINS 10 CFR 2.790 INFORMATION, NOT FOR PUBLIC DISCLOSURE, IS INTENTIONALLY LEFT BLANK.
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