ML20012F262
| ML20012F262 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/02/1990 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| C311-90-2040, NUDOCS 9004110035 | |
| Download: ML20012F262 (3) | |
Text
'
ej.
OPU Nueleet Corporellen G p Nuclear
- e9'.;a=
Middletown, Pennsylvania 17067 0191 717 944 7621 TELEX 84 2306 Writer's Direct Dial Number:
April 2, 1990 0311-90-2040 U. S. Nuclear Regulatory Commission Attn Document Control Desk Washington, DC 20555
Dear Sir:
Throo Mile Island Nuclear Station, Unit (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Response to Notice of Violation in Inspection Report 89-26 Enclosed is GPUN's response to the Notico of Violation in Appendix A to Inspection Report 89-26.
Sincoroly, hh
{W H. D. Hu ill Vice President and Director, TMI-l HDH/MRK Attachment Notarh! Seal cc J. Stolz gFL
.N Puth:
R. Hernan M
1
- , ggy, yConviissbnExpwFeb.
I Sworn and subscribed to before mcfphis d'"O day of
/( i% A 1990.
/
.Nhb At 900411dO35 000402 PDR ADOCK 05000289 I
O PDC i
GPU Nuclear Corporation is a subsidiary of the General Publlc Utilities Corporation 1
C311-90-2040 Page 1 of 2 Notice of Violation Technical Specification 6.8.1 requires that written procedures shall be established and implemented for surveillance and test i
activities of equipment that affects nuclear safety.
Contrary to the above, on January 6, 1990, the licensee failed to adequately establish and implement Surveillance Procedure (SP) 1303-11.18B " Reactor Building (RB) Local Leak Rate Testing - RB Spray Pressure Instrumentation".
Step 6.5 did not provide adequate and complete guidance for resetting the "A" Reactor Protection System (RPS) channel.
This resulted in an inadvertent RPS actuation.
Additionally, step 6.11 which resets Engineered Safeguards Actuation System (ESAS) Channel 3B was improperly completed in that this resulted in an inadvertent Engineered Safeguards Actuation System actuation.
This is a severity level IV violation (Supplement I).
GPUN Resoonse The event which resulted in this violation was reported to the NRC on February 6, 1990 as Licensee Event Report (LER) 90-001-00. This was in reference to the inadvertent Reactor Protection System (RPS) and Emergency Safeguarde Actuation System (ESAS) actuations which occurred on January 7, 1990 during the performance of a surveillance while shutdown for the TMI-1 Cycle 8 Refueling (8R)
Outage.
The LER stated that the cause of the RPS actuation was inadequate procedure detail in combination with personnel error while the ESAS actuation was caused only by personnel error.
GPUN agrees with the violation, but we disagree with the NRC's statements in the cover letter and in the inspection summary for Inspection Report (IR) 89-26 that this violation was indicative of insufficient guidance contained in many surveillance procedures for technicians with minimal system knowledge.
In response to this event, GPUN developed a list of surveillance i
procedures which we felt could potentially result in an inadvertent safety system actuation (Reactor Protection System, Emergency Safeguards Actuation System, Heat Sink Protection System, or Radiation Monitoring System).
Sixty nine procedures were identified.
These procedures have been reviewed to identify any deficiencies that could result in inadvertent safety system actuation and also to determine if other enhancements would be beneficial.
Based upon this review, we have determined that the deficiency noted in Surveillance Procedure 1303-11.18B was not typical and other surveillance procedures did not contain insufficient detail for use by technicians with minimal system knowledge.
1
.-----a
l C311-90-2040 i
Page 2 of 2 l
Corrective Actions taken and Results Achieved This event was discussed with the lead foreman of each maintenance discipline.
The foremen were directed to ensure that all technicians are thoroughly briefed or adequately supervised.
This event was discussed with the operations shift supervisors who have discussed the event with their crews including the fact that we should not have proceeded after the first actuation without properly determining the cause and correcting it.
Shift supervisors have been directed to verify the bypassing and resetting of safety systems and to ensure that crews are adequately briefed.
The Plant Operations Director also met with each shift supervisor to emphasize the need for their control and cognizance of shift activities regardless of the plant's operating status (e.g., while shutdown).
There have been no recurrent eveats of this nature to date.
Corrective Actions to Prevent Recurrence 1.
GPUN's current policy will be enforced such that maintenance foremen will ensure that all technicians are thoroughly briefed or adequately supervised.
2.
GPUN's policy of shift supervisor involvement in the bypassing and resetting of safety systems is being expanded to include shutdown conditions.
3.
Surveillance Procedure 1303-11.18B will be revised to include sufficient detail.
Date of Full Comoliance As stated above, GPUN believes the only procedure that was deficient was Surveillance Procedure (SP) 1303-11.18B " Reactor Building (RB) Local Leak Rate Testing - RB Spray Pressure Instrumentation".
This procedure is being re-written to correct the problem that contributed to this event along with other enhancements.
In order to allow sufficient time for the normal review process, this procedure is currently scheduled to be completed in September, 1990.
The next performance of this procedure will not be until October, 1991.
Therefore, the necessary changes to 1303-11.18B will be effective before the procedure is used again.
I i
(
-