ML20195J021
| ML20195J021 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/13/1998 |
| From: | Eselgroth P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Langenbach J GENERAL PUBLIC UTILITIES CORP. |
| References | |
| 50-289-97-10, NUDOCS 9811240177 | |
| Download: ML20195J021 (2) | |
See also: IR 05000289/1997010
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November 13,1998
l Mr. J. Langenbach
Vice President and Director-
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GPU Nuclear, Inc.
"Phreo Mile Island Nuclear Station
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M O. Box 480
Middletown, Pennsylvania 17057-0480
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SUBJECT:
. INTEGRATED INSPECTION 50-289/97-10
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Dear Mr. Langenbach:
This letter refers to your April 17,1998 correspondence, in response to our
. February 26,1998 letter.
Thank you for informing us of the corrective and preventive actions documented in your
letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
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Sincerely,
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Original Signed By:
Peter W. Eselgroth, Chief
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hojects Branch 7 '
Division of Reactor Projects
Docket No.: 50-289
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cc w/o cv of Licensee Resnonse Letter:
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M. J. Ross, Director, Operations and Phlintenance
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D. Smith, PDMS Manager
M. Laggart, Manager, Licensing and Vendor Audits
J. Wetmore, Manager, Nuclear Safety and Licensing
n/cv of Licensee Resoonse Letter:
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- E. L. Blake, Shaw, Pittman, Potts and Trowbridge (Legal Counsel for GPUN)
TMl-Alert (TMIA)
Commonwealth of Pennsylvania
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9811240177 981113
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Distribution w/cv of Licensee Response letter:
Region i Docket Room (with r v.tcurrences)
Nuclear Safety Information Center (NSIC)
PUBLIC
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NRC Resident inspector
H. Miller, RA/W. Axelson, DRA
P. Eselgroth, '1RP
N. Perry, C
C. O'Danielt, .
S. McCabe, OE00_
C. Thomas, PD1-3, NRR
T. Colburn, PD1-3, NRR
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R. Eaton, PDI-3, NRR
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S. Weiss, NRR
L. Thonus, NRR
. R. Correia, NRR
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DOCDESK
Inspection Program Branch, NRR (IPAS)
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DOCUMENT NAME: G:\\ BRANCH 7\\REPLYLTR\\TMl971D.RPY
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T3 recohre a copy of this document, Indicate in the box: "C" = Copy withvut attachment / enclosure
'E" = Copy with attachment / enclosure
"N' = No copy
GFFICE
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NAME
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PDEliFroth
DATE
n/9 /98
- /it /98
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OFFICIAL RECORD COPY
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GPU Nuclear,Inc.
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Route 441 south
NUCLEAN
Post Office Box 480
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Middletown, PA 17057-0480
Tel 717-944 7621
April 17,1998
1920-98-20123, Revised
,U.S. Nuclear Regulatory Commission
Attention: Document Control Desk
Washington, DC 20555
Dear Sir:
Subject:
Three Mile Island Nuclear Station, Unit 1, (TMI-1)
Operating License No. DPR-50
Docket No. 50-289
Response to. Notices of Violatica (NOV) 97-09-02, dated January 27,1998
And NOV 97-10-01, dated Febmary 26,1998
CORRECTED COPY
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The attachment to this letter transmits the GPU Nuclear (GPUN) Inc. responses to the NOVs
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referenced abo,'e. Each violation identified in the NOVs is addressed separately to include: (1)
the reason for the violation; (2) corrective actions taken and results achieved; (3) corrective
actions to be taken, if applicable, to avoid future violations; and (4) the dates of full compliance
achievement. The public health and safety were not affected by these events.
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The two violations involved procedural non compliance and usage issues. While we de+ ermined
that the root causes for each event were different, we have concluded that programmatic
improvements should be considered in addition to the specific actions identified in this response.
We plan to expand the list of applicable procedures required by administrative controls to be
carried and signed off during performance of plant evolutions by June 30,1998. We also plan to
conduct a self-assessment and benchmarking review of the procedural controls currently in
place. The review will consider industry guidance and good practices employed by other nuclear
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- plants to determine what changes should be made to improve procedure control or usage at TMI.
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The target date for completion of this review is September 30,1998. A schedule for the
development and implementation of requisite improvements is expected to be in place by
October 31,1998.
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1920-98-20123
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This NOV response is being submitted pursuant to the requirements of 10 CFR 2.201, and
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contains no information subject to the provisions of 10 CFR 2.790(b). If you have any questions
concerning this matter please contact Mr. G. M. Gurican, Sr. II Nuclear Safety & Licensing
Engineer, at TMI phone No. (717) 948-8753.
Sincerely,
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QNQ0
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VJames W. Langenba
Vice President and Directot, TMI
JWUGMG
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Attachment
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1920-98-20123
Page 3 of 3
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I, James W. Langenbach being duly sworn, state that I am the.TMI Vice President and an
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Officer of GPU Nuclear, Inc. and that I am duly huthorized to execute and file this response on
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behalf of GPU Nuclear. To the best of my knowledge and belief, the statements contained in
this document are true and conect. ~To the extent that these statements are not based on my
personal knowledge, they are based upon information provided by other GPU Nuclear
employees and/or consultants. Such information has been reviewed in accordance with
company practices and I believe it to be reliable.
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James W. Langenpdh
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Vice President, TMF
GPU Nuclear, Inc.
A df M B
[A Notary Public of { ~ ~ ~
Notarial Seal
Suzanne C Miklosik. Notary Public
Londonderry Twp., Dauphin Co nty
My Commission Expire? Nov.22,1999
Member,Pennsylvans Assocation of Notanes
cc:
NRC Administrator Region I
TMI Senior Resident Inspector
TMI Project Manager
File Nos.: 97105 and 98053
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CORRECTED COPY
ATTACHMENT
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RESPONSE TO NOTICES OF VIOLATION
January 27,1998, IR 50-289/97-09-02 (EA 97-533)
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And February 26,1998, IR 50-289/97-10-01
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Notice of Violation 97-09-02
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Technical Specification (TS) 6.8.1 requires, in part, that Written procedures be
implemented covering the applicable procedures recommended in Appendix 'A' of
Regulatory Guide 1.33, Revision 2, Febmary 1978. Regulatory Guide 1.33, Appendix
'A', Section 3.0 recommends, in part, instructions for filling and venting the reactor
coolant system (RCS) and for operation of decay heat removal systems.
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Operating procedure (OP) 1103-2, " Fill and Vent of the Reactor Coolant System," section
3.1.2, step 17.c, requires, in part, that when the level at the center control rod drive
mechanism (CRDM) is observed at one to two feet below the top, terminate the RCS fill
and' hold level.
OP 1104-4, " Decay Heat Removal System," section II of Enclosure 2, "Make Up to the
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RCS Directly from the BWST," provides a caution that make up to the RCS directly from
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the borated water storage tank (BWST) must be carefully monitored since large volumes
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of water can be transferred very rapidly. Step 1 of section II states, in part, that
controlling the level in the RCS using this method is not considered to be, nor should it
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be, used as a major RCS fill and vent method.
Contrary to the above, on October 15,1997, the licensee failed to properly implement
operating procedures 1103-2 and 1104-4 while filling and venting the RCS following a
refueling outage. Specifically, while filling the RCS from the reactor coolant bleed tank
(RCBT) in accordance with OP 1103-2, make up to the RCS was established directly
from the BWST, contrary to the instructions in Enclosure 2 of OP 1104-4. The additional
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makeup caused a prompt rise in pressurizer level. Even though the operators observed
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the level increase in tne control room terminated the RCS fill from the RCBT, the
makeup from the BWST was not immediately terminated due to communications
difficulties. Consequently, approximately 50 gallons of RCS water overflowed out of the
CRDM vents onto the reactor vessel head area.
GPUN Response:
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Rusong for Violation
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- GPUN agrees with the violation. In this event, the Shift Supervisor (SS) used poor
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judgement and inappropriate procedural implementation during the performance of the
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RCS fill and vent evolution by establishing a flow path from the BWST at a time when it
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was inappropriate to do so because of the potential for overfill. The SS did not
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u..derstand Management's expectation that the BWST would not be used for filling the
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RCS when the pressurizer level was above 100 inches; and, the SS incorrectly assumed
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that he was filling to 390 inches and thought that he needed much more water than was
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. available in the Reactor Coolant Bleed Tank.
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In addition, the evolution was started during a shiR turnover, and supervisory methods
and verbal communications between team members were less than adequate; also, the use
ofimproper communications equipment contributed to a delay in event termination.
2.
Corrective steos taken and results achieved.
The inappropriate actions of the Shift Supervisor (SS) in this event were
a.
reviewed with the individual, with special emphasis placed on his behavior
and opportunities missed that would have prevented this event. The SS was
disciplined and directed to participate in a personal development program to
improve both teamwork and communications techniques. Specifically, the
improvement program addressed the need to learn positive feedback
techniques and abilities that foster acceptance of constructive criticism and
teamwork coherence as both a member and team leader of the crew.
b.
. A revision of OP 1104-4 has been made to provide a more specific warning that
addresses the use of the BWST as a fill source to strictly prohibit its use when the
pressurizer level is at 100 inches or above. This revision also adds signotT
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requirements to specific steps within the procedure.
c.
Management has issued instmetions to all crews concerning its expectations with
respect to the inappropriateness of performing significant plant evolutions while a
shin turnover is in progress. Management has reemphasized the need for strict
procedural compliance as well as the need to have a questioning attitude.
d.
Procedural compliance has been stressed with all crews including the
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requirements: to have procedures available; to properly signoff procedural steps
for significant evolutions; and, when procedures are not available, to obtain the
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procedure and resolve any questionable issue prior to conduct of the evolution.
These Management expectations were documented in an internal memorandum to
all departments from the Director of Operations & Maintenance.
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e.
Communication enhancements have been made with the modification of the
format for conducting the Operations Department outage shiR turnover meeting.
This has been accomplished by the inclusion of a final summary " repeat back" by
the oncoming Shin Supervisor, prior to concluding the meeting, in order to ensure
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understanding of direction and intent,
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By memo from the Plant Operations Director to all Shin Supervisors and crews
the use of appropriate communications equipment, specifically the M&I phone
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system, are to be used for significant plant evolutions that require numerous
transmissions of detailed information.
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3.
. Corrective steps to be taken to avoid further violations.
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The listing of significant evolutions requiring specific procedures for
a.
implementation identified in AP-100lG, " Procedure Utilization," will be
expanded to meet Management's expectations informally communicated by the
Director of Operations and Maintenance via internal memorandum dated March
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3,1998. This expansion of AP-100lG will increase the number of evolutions that
require having a procedure in-hand when performing the evolution.
b.
(1) To achieve a higher standard of administrative controls, GPUN intends to
make programmatic improvements to strengthen procedural compliance and
documentation. A self-assessment and benchmarking review of procedural
controls and usage at TMI will be conducted, considering industry good practices
and guidane. (2) The implementation of any requisite improvements in
procedural controls / usage resulting therefrom will be instituted by changes to
affected procedures.
4.
Dates of full compliance.
Full compliance has been achieved
Cerrective action 3.a will be completed by June 30,1998. Corrective action 3.b (1) will
be completed by September 30,1998; and, the schedule for implementation of the
requisite procedure changes 3.b.(2) will be developed by October 31,1998.
Notice of Violation 97-10-01
Technical Specifications 6.5.1.1, " Technical Review and Control," and 6.8.2,
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" Procedures and Programs," require, in part, that any substantive change.;, Ncluding the
change ofintent to procedures that affect nuclear safety, shall be reviewed and approved
prior to implementation.
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Contrary to the above, on November 20,1997, GPUN did not review and approve a
substantive change to an existing inservice test (IST) surveillance procedure 1300-3K,
"IST of Reactor River Water Pumps and Valves," before the closure of the reactor
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building emergency cooler inlet and outlet valves to conduct a leak test. The IST
procedure waa written and approved to determine the cooler inlet and outlet valve open
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and closed times, but did not allow the valves to be closed for the seven hour leak test.
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GPUh Response:
1.
Reasons for Violation
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GPUN concurs there was a violation of Technical Specification 6.5.1.1 and 6.8.2.
However, for accuracy it should be noted that on November 20,1997 the Operators did
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not rely upon use of the Surveillance Procedure 1300-3K to conduct the investigation of
leakage from the Nuclear Services system. This trouble shooting activity was performed
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using the guidance of AP-1029 and OP-100lG. On November 24,1997 the Operators
did use SP-1300-3K for guidance to conduct valve cycling as allowed by OP-100lJ,
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" Tech Spec Surveillance Program Testing," which states: "where the intent of a test is
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other than to satisfy a TS surveillance testing requirement, the appropriate TS
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surveillance procedure may be used for instructional guidance and as a vehicle to
document performance."
Nevertheless, GPUN has determined that on November 20,1997 the requirements of
procedures AP-1029," Conduct of Operations," and OP-100lG, " Procedure Utilization,"
were not met, in that the crew's determination that there would be no adverse affects on
the operability of the RR system due to closing of the RR-V-3s was not logged. Prior to
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closing the valves the crew did discuss and determine that there would be no adverse
atTects on operability because an ES signal would cause the valves to open in the evem of
a LOCA, if the valves were closed. However, the procedurally required logging of this
determination did not take place.
GPUN has also determined that AP-1029 currently does not contain adequate guidance
and controls for the conduct of trouble-shooting activities. It is Management's
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expectation that evolutions of this nature would be controlled by means of a trouble
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shooting plan based on appropriate guidance using a graded approach and/or by a Special
Temporary Procedun (STP). The STP process is designed to assure that proper
precautions are established, and that reviews of design basis requirements and other
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safety considerations are conducted prior to executing the STP.
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In addition, a contributing cause for not initiating a STP for this plant evolution was the
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failure to effectively translate a change in design basis assumptions into operating
procedures (n.b., the necessity for the assumption was later negated by reanalysis).
Specifically, the initial assumption made was that an overpressure on the Reactor
Building Emergency Coolers needed to be maintained in order to address GL 96-06
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concerns. This assumption was not identified by the System Performance Team (SPT)
for consideration of potential impact upon operating procedures when the SPT performed
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the analyses prepared for the original Generic Letter response.
2.
Corrective steps taken and results achieved.
a.
Management has re-emphasized its expectations that crews are to comply with the
requirements for obtaining permission and logging all work related to the
performance of evolutions not covered by written procedures, and to be aware. of
the administrative requirements and in particularthe documentation requirements
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Corrective steos to be taken to avoid further violations.
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3.
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a.
GPUN will develop new/ revised guidance to effectively strengthen work controls
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relevant to the conduct of trouble shooting within AP-1029," Conduct of
Operations." The guidance on trouble shooting considerations will address more
formally, Management's expectations as previously outlined in an internal
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memorandum dated March 3,1998, from the Director of Operations and
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Maintenance, and will be based on a graded approach for the use of a trouble
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shooting plan and/or an STP.
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.b.
This event will be incorporated into the operating experience presentations for
Licensed Operator training and requalincation, as well as, in the Engineering
Support Personnel training. The event review will emphasize how the change
control processes should provide identification of the relationship between the
design basis assumptions and the operational requirements for plant systems.
A self-assessment and benchmarking review of procedural usage as described in
c.
Corrective Action 3.a for the response to NOV 97-09-02 above will be conducted.
d.
The System Performance Teams (SPTs) are accountable for ensuring that changes
made in desigii assumptions, as related to Operations or Ma~intenance activities
are thoroughly evaluated and, when needed, incorporated into plant procedures,
training, and design documents. The SPTs minimum membership includes
representatives from Operations, Maintenance, and Engineering departments.
GPUN will review this specific event with the System Engineers, who are the
SPT leaders. The review will emphasize how the change review process could
have provided identification of the relationship between the design basis
assumptions and the operational requirements for the system. Additional
guidance will be incorporated into the next revision to the System Engineering
Guideline (Document #990-2471) to capture the lessons learned from this event.
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The SPT and System Engineer review goes above and beyond the existing
10CFR50.59 review requirements as provided by the GPUN Safety Review
Processes that are required for plant modifications and/or procedure changes.
4.
Dates of full comoliance:
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Full compliance has been achieved.
Corrective actions 3.a and 3.b to avoid future violations related to this NOV will be
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completed by December 31,1998. Corrective action 3.c will be completed as identified
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above under corrective action 3.b for NOV 97-09-02, in two parts, namely: the self-
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assessment study is scheduled for September 30,1998 and its implementation schedule
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for October 31,1998. Corrective action 3.d will be achieved by June 30,1998.
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