ML20032C531
| ML20032C531 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/11/1981 |
| From: | Hovey G METROPOLITAN EDISON CO. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20032C530 | List: |
| References | |
| LL2-81-0238, LL2-81-238, NUDOCS 8111100541 | |
| Download: ML20032C531 (6) | |
Text
8 4
Metropolitan Edison Company Post Office Box 480 Il Middletown, Pennsylvania 17057 Writer's Direct Dial Number October 11, 1981 LL2-81-0238 Office of Inspection and Enforcement Attn: Mr. Ronald C. Haynes, Director Region I U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Sir:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Inspection Report 81-12 This is in response to the subject Inspection Report issued September 10, 1981 and is being submitted in accordance with the provisions of the report and our letters of September 1,1981 and October 2,1981 (LL2-81-0224 and LL2-81-0234 respectively).
Item A - Apparent Violation (Severity Level IV)
Contrary to the requirements of AP1001 and the Quality Assurance Plan (QAP) an uncontrolled drawing was used for operation of a system important to safety. Additionally, uncontrolled drawings (information only drawings stamped in red) were posted in the 3DS pool area and near the SPC operating panel in the control room.
Response
To prevent further violations regarding usage of other than controlled drawings for operations, the Operations Group will be reinstructed on the proper drawing controls as required by AP1001, TMI Document Control. With regards to the posted drawings, the drawings not stamped
" Controlled Copy" in red have been removed from the areas indicated in the subject violation.
In addition, all operating areas of the plant have been inspected for drawings not stamped " Controlled Copy" in red.
All such drawings were removed. The corrective actions described above have been completed as of the cate of this letter.
hbhkbo 0$000 Q
Metropohtan Edison Company is a Member of the General Put2c Utaties System
Mr.' Ronald C. Haynes LL2-81-0238 Iten B.1 - Apparent Violation (Severity Level IV)
B.1(a) Contrary to Technical Specification 6.8.1, Operating Procedure (OP) 2104-8.0 Rev.- 0 Submerged Demineralizer System Operational Guicelines was not properly implemented in that on June 30, 1981, as of approximately 10:00 p.m., the Fuel Handling Building (FHB) truck bay door was not closed in accordance with paragraph 3.11 of '.he referenced procedure.
Response
At the time of the indicated viclation, the transfer of the water in~ "B" RCBT to the tank farm was in progress in accordance with OP 2104-4.123, Transfer of RCBT's to Tank Farm.
The violation, as indicated, was a violation of OP 2104-8.0 Rev. O, SDS Operational Guidlines.
OP 2104-4.123 does not refer to or include the applicable requirements contained in GP 2104-8.0.
This violation was procedural in scope since the procedure being used at the time (OP 2]n4-4.123) did not contain the limits and precautions required by OP 2104-8.0. To prevent a recurrence of this problem all applicable SDS procedures will be reviewed and the requirements contained in GP 2104-8.0 will be incorporateo into the applicable procedure (s). This action will be complete by November 15, 1981.
L.!sb) Contrary to Technical Specification 6.8.1, Operating Procedure (OP) 2104-8.15 Rev. O " Submerged Ion Exchange (IX) System Operation using IX 1A or IX 1A and 1B only" was not properly implemented in that on July 16, 1981, as of approximately 2:00 a.m., the SDS pool area radiation monitor, CN-RIT-IX-03, was removed from service during the processing.of radicactive waste U1 rough SDS.
Response
As indicated in the stated item of apparent noncompliance, the requirement that SDS pool area radiation monitor CN-RIT-IX-03 be operational is a prerequisite for SDS operation.
Our operators have been given guidance that a prerequisite is the means to identify those independent actions or procedures which shall be completed and plant conditions which shall exist prior to the use of the subject procedure.
Depending on the evolution required by the procedure, once in use, the stated prerequisite may be altered within the bounos of safety and good cperating practice.
t
[
e
~
Mr. Ronald C. Haynes LL2-81-0238 If the item identified is such that a change will alter the ef fective use of the procedure, while in use, or if safety and/or good operating practice can be affected by the change, then the item is not a prerequisite but a limit and is included in the procedure as s Linit and Precaution and not as a Prerequisite.
Since the subject of this alleged violation is a cFange of prerequisite and not a. limit or precaution and the removal from service of CN-RIT-IX-03 was backed up by four other monitors in the same general area, it was determined that no violation of procedures or safety had occurred and that the operations perscnnel performed in accordance with their guidance.
It is also recognized that CN-RIT-IX-03 provides an interlocking function with IX-V24 (Inlet isolation valve to Ion Exchange Vessels) and that more specific direction involving this detector is required.
To insure this direction is given, a change to CP's 2104-8.15 and 2104-8.1 will be inccrporated requiring specific action by the operator when this detector is taken cut of service.
This corrective action will be complete by November 15, 1981.
Item E.2 - Apparent Violation (Severity Level V)
Contrary ts Iechnical Soecification 6.8.2, 6.8.3.1 and Administrative Procedure (AP) 1001, mccifications to CP 2104-4.123 were effected cn June 30, 1981 nnd July 1,1981 in that required monitoring and control functions were performed but not in the manner specifico in the procedure and no Procedure Change Rcquest (PCR) or Temporary Change Notice (TCN) was issued.
The modifications were documented as deviations from the procedure in the Shif t Foreman's Leg.
l Respcnse:
The cause cf both cit'tions in this section aas due to the individual Shif t Forctun's misuaderstanding of the requirements given in AP 1060, Procedure L3 age and Impleme..tation. At the time of the violation AP 1060 hao recently been approved and implemented. All operations personnel had teen instructed in the centents of AP 1060 prior to its implementation.
l The Shif t Foreren involved did not get a clarification of his interpretation of this procedure which resulted in the inoicatea finding.
Corrective action taken included instruction to the Shift Foreman involved on the requirements of AP 1060 ano the inclusion of this procedure in the Operator Requalification Program. Additional 1~y, a TCN & PCR in accordance with AP 1001, Document Control has been issuec to GP 2104-4.123 to incorporate those applicable requirements indicated in this violation.
l l
k-
Mr. Ronald C. haynes LL2-81-0238 1
1 Item C - Apparent Violation ('
verity Level V)
Contrary to the requiren.vots of AP 1001~ and the Quality Assurance Plan (QAP), between June 30, 1981 and July 2,1981 uncontrolled instructions and procedures were posted or used arcund the SDS pool area as noted below.
3 Item C.1 Various copies of a handwritten, unreviewed and unapproved pit G (Particulate Iodine tbble. Gas) bbnitor Operation Procedure at the SDS Of f Gas System PING monitor were posted and were at the operator's desk.
Response
~
he are still reviewing this situation and have not as yet determined the root cause of this apparent violation of procedural controls. We will expeditiously complete the review and submit our response.
In any event 1
our response will be submitted by October 30, 1981.
f Item C.2 Table 1.5.1.3, Calculated Volume vs. Liquid Level - Waste Storage Tanks (WG-T-2A/28/2C/2D) Upper Tanks, to GP 2104-4.50, Fuel Pool Waste Storage System, was posted on the east wall of the Fuel Handling Building (FFB) near the tank level manometer and Helse gage indicator.
Revision 0 was posted while Revision 4, dated January 4,1980 was the effective table. The posted table was not marked " controlled copy".
r i
Response
Our response to Item A of the Inspection Report applies to this item as well.
Item C.3 Two different gage correlations.ga11cns vs. inches) for WG-LI-1A (SDS Feed Tank Level Indicator) were posted at the SDS Feed Pump centrol panel and at the operators' desk. Both tables applied to the same gage.
thither correlation was marked " controlled copy".
l
Response
Our response to Item A of this Inspection Report applies to this item as well.
l-
Mr. Ronald C. Haynes LL2-81-0238 Item C.4 OP 2104-8.4, Revision 0, May 1,1981, SDS Monitor Tank, was distributed for use in the plant without1 review and approval by NRC onsite staf f as required by Technical Specifications.
Response
This procedure was issued for testing purposes only on May 1,1981. The objective was to test the SDS Monitoring Tank System and simultaneously red-line the procedure. On July 5, 1981, during the fill and vcnt of the SCS system, it was decided to use the water in the monitoring tanks vice creating additional radioactive waste water from the Demineralized Water System. During the period in which the valve lineup was being completed, it was noted that this procedure did not receive NRC review and approval and use of the procedure was discontinued. No further corrective action is contemplated.
Additionally, in the transmittal letter for this Inspection Report we were requested to describe those actions taken or planned to improve the effectiveness of our management control systems in -the drawing control area.
We are forming a task force to evaluate, among other things, our document
~
control mechanisms.
It is a function of this task force to identify those areas requiring improvement in our current occument control mechanisms. he will communicate significant milestones t_ the Senior Resident Inspector, TMIPO, USNRC and upon completion of the task force, submit a final response tc the subject request.
i (5iqerely, L'
- ey VI -President and rector, TMI-2 GKH:SDC:k1k Enclosure cc:
L. H. Barrett, Ceputy Program Director Dr. B. J. Snyder, Program Director, THI Program Office
r.
METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER AND LIGHT COMPANY AND PENNSYLVANIA ELECTRIC COMPANY THREE MILE ISLAND NUCLEAR STATION, UNIT II Operating License No. DPR-73 Docket No. 50-320 This letter is submitted in support of the Nuclear Regulatory Commiss.?an request concerning the September 1, 1981 letter transmitting Inspection Report 50-320/81-12.
The response to the subject Inspection is attached. Further, all statements contained in these responses have been reviewed and all such statements made and matters set forth therein are true and correct to the best of my knowledge, information and belief.
By
[ Ac Dir Wtor, TML-2 Sworn and subscribed to me this 11 A day
&ct ntA.0, 1981.
By h h Mw Notary Public 4
DARLA JEAN B(RRY. NOTARY PUGilC MIDDLETOWN B080. DAUPHIN COUNTY MT COMut154006 (EPIRES JUNE 17. 1935 Moebes, Peen.yheena Associaten of Notmes