ML20079K272

Responds to NRC Re Violations Noted in Insp Rept 50-289/91-18 on 910721-0810.Corrective Actions:Procedure Change Request 1-MT-91-8674 Initiated to Incorporate Changes to Reactor Protection Procedure Sp 1303-4.1, Rps

ML20079K272
Person / Time
Site:	Three Mile Island
Issue date:	10/11/1991
From:	Broughton T GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
C311-91-2119, NUDOCS 9110210214
Download: ML20079K272 (4)

Text

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4 GPU Nuclear Corporation u Nuclear =orar8o

%ddictow n, Pennsylvania 17057 0191 717 944 7621 1ELEX 84 2386 Writer's 06 cct Dial Numtier (717) 948-8005 October ll, 1991 C311-91-2119 U. S. Nuclear Regulatory Congnission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

Three Mile Island Nuclear Station, Unit 1 (IMl-1)

Operating license No. DPR-50 Docket No. 50-289 Response to Notice of Violation in Inspection Report 91-18 1his letter transmits GPUN's response to the Notice of Violation in Appendix A to inspection Report 91-18.

Sincerely, t

T.G.Brofjhton h /A Vice President & Director, IMl-1 WGH:

Attachment cc: Administrator, Region 1 IM1-1 Senior Project Manager TMI-l Senior Resident inspector vi10:10214 cm 0

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GPU Nuciear Corporation is a t,utwntary of Geru ral Putm. UMt<es (' orpomon

HElROPOL'.1AN EDISDN COMPANY JERSEY CENTRAL POWER AND LIGili COMPANY PENNSYLVANIA ELEC1RIC COMPANY GENERAL PUBLIC U11LITIES NUCLEAR COPR6.ATION Three Mile Island Nucicar Station, Unit 1 (1HI-1)

Operating License No. DPR-50 Occket No. 50-289 Response to the Notice of Violation in inspection Report 91-18 1his letter is submitted in response to the Notice of Violation in inspection Report 91-18. Routine Monthly inspection for the period July 21 through August 10, 1991 for THI-l dated September 11, 1991. All statements contained in this res)onse have been reviewed, and all such statements made and matter set forth tiercin are true and correct to the best of my knowledge.

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T. G. Broughton Vice President and Director, TH1-1 Signed and sworn before me this lith day of October , 1991, (fki/6[Q[he v' Xdof>L Mut Kk Nh tary Pdeo u %,%t@@lt%

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'C311-91-2119 Attachment Page 1 of 2 Holist _of Violation Technical Sperification 6.8.1.b requires that written procedures be established rad implemented for surveillance and test activities of equipment that affects nuclear safety. To implement this requirement for the Reactor Protection System, the licensee established Surveilla",ce Procedure (SP) 1304-4.1 [ sic], " Reactor Protection System," revision 69, April 5, 1991.

Contrary to the above, on July 24, 1991, the licensee failed to implement Reactor Protection Procedure 1301-4.1 [ sic), step 8.10.7.9, which resets motor faults or the electronic trips in the control rod drive power supply, which led to a reactor trip. The Instrument and Control technician failed to reset the electronic trips in step 8.10.7.9 and marked this step not applicable.

iip.MLBftsnollis GPU Nuclear agrees with this violation as presented in Inspection Report (IR) 91-18.

ftitckaround The violatio.: occurred during performance of " Reactor Protection System" Surveillance Procedure (SP) 1303-4.1 when an Instrument and Controls (l&C) technician failed to cxecute a step in accordance with written guidance provided in the procedure. Procedure step 8.10.7.9, requiring that the motor power supply faults or electronic trips be reset by pressing the Fault Reset button on the Control Rod Drive (CRD) control panel, was not performed, instead, the technician misunderstooo the procedure step, marked it *N/A" and proceeded through the remaining steps. Consequently the CRD power supply was not reenergized.

Realo1Lfcr the Violatioll The reason for the violation was procedure noncompliance. The 1&C technician failed to complete step 8.10.7.9 and annotated it instead, as "N/A." The individual transferred to THl-1 from THI-2 one year ago and was trained but relatively inexperienced in the performance of the assigned task. His previous experience was in the position of " Performer" on the two man team assigned to perform SP 1303-4.1. On this occasion, he was assigned to the position of " Reader / Data Taker" and upon reaching step 8.10.7.9 (a step he had performed on several occasions), he misunderstood the intent of the wording and responded inappropriately.

'C311-91-2119 Attachment Page 2 of 2 Corrective Actions-Taken and Results Achieved As a result of the procedure noncompliance, the following corrective actions were taken:

1) SP 1303-4.1 step, 8.10.7.9 was revised via a Temporary Change Notice (TCH) on July 29, 1991 to clarify the wording so that the intended action is performed.

2) The technician involved was counselled by Plant Hateriel Department supervisory personnel on the importance of procedure understanding and use.

These actions will lessen the likelihood of the misinterpretation of step 8.10.7.9 during performance of SP 1303-4.1 in the future.

Corrective Actions to Prevent Recurrence Procedure Change Request (PCR) 1-MT-91-8674 has been initiated to incorporate the changes to SP 1303-4.1 by the TCN. The corrective actions taken as described above and the permanent revision to SP 1303-4.1 are considered adequate to prevent recurrence of this violation.

Date of Full Comoliance Corrective action will be complete and full compliance achieved with the issuance of the PCR. The PCR will be issued by October 27, 1991.

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