ML20128D634

Responds to Violations Noted in Insp Rept 50-320/85-01. Corrective Actions:Review of Major Plant Electrical Busses, Unit Substations & Motor Control Ctrs Conducted to Determine If Similar Tagging Problems Existed

ML20128D634
Person / Time
Site:	Crane
Issue date:	05/03/1985
From:	Standerfer F GENERAL PUBLIC UTILITIES CORP.
To:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
0245A, 245A, 4410-85-L-0104, 4410-85-L-104, NUDOCS 8505290145
Download: ML20128D634 (4)

Text

r o

4 GPU Nuclear Corporation NggIg{

Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84 2386 Writer's Direct D.ai number:

(717) 948-8461 4410-85-L-0104 Document ID 0245A May 3, 1985 Office of Inspection and Enforcement Attn: Dr. T. E. Murley Regional Adn.inistrator US Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406

Dear Dr. Murley:

Three Mile Island Nuclear Station, Unit 2 (TMI-2)

Operating License No. DPR-73 Docket No. 50-320 Inspection Report 85-01 Inspection Report 85-01, dated April 3, 1985, identified two (2) items of non-compliance. Attached is the GPU Nuclear response to each citation.

Sincerely,

/'

u F. R. Standerfer Vice President / Director, TMI-2 FRS/JCA/eml Attachments cc: Program Director - TMI Program Office, Dr. B. J. Snyder Deputy Program Director - TM1 Program Office, Dr. W. D. Travers 8505290145 850503 PDR ADOCK 05000320 G

PDR

-l 2 - L1/

GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation ag L__

m- -

y ATTACHENT,

. 4 4410-85-L-0104-j STATEENT OF VOILATION

The--Order for Modification of License, dated July 20, 1979, as amended by the Order, dated'Feoruary 11,'1980,- states,-in part

... Pending further-amendment of'the Facility Operating License, the licensee shall maintain the

. facility'in accordance with:the. requirements set forth'in Attachment 1..."

(proposed Technical Specification,eAppenoix A to License No. DPR-73).: The proposed Technical-Specification 6.8.1.a states in part: " Written procedures ishall?be... implemented covering... the applicable procedures recommended-in

. Appendix A of Regulatory Guide 1.33, Revision 2, February 1978..."

Specific ~

~ ctivities referenced in Regulatory Guide 1.33 include equipment control a

'(e.g., locking and tagging).

3:

-Administrative Procedure 4000-ADM-3020.06, Unit Facilities. Status Tagging, Revision:1, effective March 30, 1984, paragraph 4.3 requires,'in part, that-Do-Not-Operate tags are to be used on the component,' control switch or other Ldevice which presents a condition undesirable to plant operation or which.

requires maintenance, repair, test, or calibration prior to resuming operation.

Contrary to the above, from September 14, 1984 through January 23, 1985,-the~

breaker for DH-V-5A was inoperable and a Do-Not-Operate tag was not used on the device.

This_is a Severity Level V Violation (Supplement I).

~ ~

GPU NUCLEAR RESPONSE GPU Nuclear ack'nowledges that the failure to place a Do-Not-Operate tag on the-

' breaker controls for UH-V-5A represents a breakdown :in the' implementation of certainl administrative control requirements.- In this' case, due to the

' potential personnel nazard which would have been associated with breaker closure, a Do-Not-Operate tag should have been placed on the breaker control.

'In' light of this condition, TMi-2 Operations personnel performed a complete 1

review of.all major plant electrical busses, Unit Substations and Motor Control Centers to determine-if conditions similar to the cited condition existed elsewhere in the plant. As a. result of this review, no similar icondition~(i.e., an open, un-tagged breaker which would' represent a potential personnel hazard if operated)'was identified.<'However, this revieu did

. identify a number of breakers which were open and were not~ status-. tagged. The majority of these breakers involved. systems on the secondary side of the plant-

=

which are no longer operated.. None of these identified cases involved damaged equipment.

To c'onply with the procedural requirements of TMI-2 ' Administrative Procedure 4000-ADM-3020.06, Unit Facilities Status Tagging, those breakers which

correspond to. shutdown systems that have been identified as open will be properly status tagged. Tags.will indicate that the systems are in a shutdown condition. '. Action is anticipated to be conpleted by July 31, 1985.

m

~

ATTACHENT 4410-85-L-0104

. c. ;

- STATEENT OF VIOLATION

The Order for Modifica' tion of License, dated July 20, 1979, as amended by the Order dated February 11, 1980, states,'.in part:

... Pending further Amendment of the Facility Operating License, the licensee shall maintain the facility in accordance with requirements set forth in Attachment 1..."

(proposed. Technical. Specifications, Appendix A to License No. OPR-73).

Proposed Technical Specifications,. Appendix A,-Section 6.8.1, requires, in

- spart, that " written procedures ~be... implemented:... covering the activities referenced in Regulatory Guide'1 33, Appendix A, Revision 2, February 1978,'

'and the Unit.2 Radiation Protection Plan." Specific activities referenced in

.Hegulatory Guide'l.33 include administrative procedures,~ authorities and responsibilities-for safe operation.

m

- Radiological Controls Procedure 9200-ADM-4110.04, Radiation _ Work Permit,-

,Section 4.22: requires,-that thJ control point Health Physics ( P) Technician

. review the dose available for individuals entering Radiation Work Permit (RWP) areas.

'ontrary to this requirement on February 13, 1985, the Reactor Building C

control point P technician failed to check.the dose available for an individual and allowed an entry into a Radiation Work Permit (RWP) area which resulted inla accrued dose in excess of GPU Nuclear administrative dose limits of 1000, mrem / quarter.

This'is:a Severit/ Level V Violation (Supplement III).

GPU NUCLEAR RESPONSE The primary cause of-this violation was an error by the Control Point technician; he. failed to recognize that.the worker in question had

. insufficient available dose to perform the assigned job without exceeding the 1000 mrem quarterly administrative dose. In response to tnis event, the following actions have been taken:

..The TLD of the individual worker involved was immediately processed.

. The Control Point' technic'ian who improperly allowed the: worker to enter:

the Reactor. Building (RB) without sufficient availaule dose was

~

i disciplined.

The Radiological Controls Reactor Building Coordinator:was assigned the specific responsibility to ensure that each person entering the RB has-sufficient available dose remaining to perform the assigned job. 'This Ldesignation of responsibility does not relieve the-Control Point

+

' technician of his responsibility to check the available dose for each

worker; it does provide an advance verification of available dose' prior to the worker arriving at the Control Point.

The event was reviewed with all Group Radiological Controls Supervisors

~

and, Technicians.

g

.)

,*,--+....r,---,m,*..-.-L, n

-,--e po w.,rf.,c,m mmwe, n.

,w-#,,,

..y,.c.m+,-

v. m.

-+mr-,

ATTACHMENT 4410-85-L-0104

e Radiological Controls Procedure 9200-ADM-4110.01, Radiation Work Permit, is being revised to add a verification space for " Required Available Exposure" to make an RWP entry. Revision of the proceoure and full compliance is expected by July 1, 1985.

In addition to the RWP procedure change, the Rems-On-Line computer system software is to be modified to " flag" a person whose authorized available exposure does not equal or exceed the, " Required Available Exposure" indicated on the Radiation Work Permit form. The target date for completion of the Rems-On-Line computer system modification is July 1, 1985.

GPU Nuclear considers that the actions taken to date are adequate to prevent recurrence of this problem. The actions planned for the future will provide an additional margin of assurance to preclude a worker from exceeding the administrative dose level.