ML20207K910

Notice of Violation from Insp on 860908-1003

ML20207K910
Person / Time
Site:	Three Mile Island
Issue date:	12/31/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207K870	List: IR 05000289/1986017 ML20207K866 ML20207K910
References
50-289-86-17, NUDOCS 8701090557
Download: ML20207K910 (4)

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i APPENDIX A NOTICE OF VIOLATION GPU Nuclear Corporation Docket No. 50-289 Three Mile Island, Unit No. 1 License No. DRP-50 As a result of result of an inspection conducted on September 8 - October 3, 1986, and, in a.ccordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the following violations were identified.:

A. Technical Specification 6.8.1 states, " Written procedures important to safety shall be implemented... covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978...." Appendix A of Regulatory Guide 1.33, Revision 4, recommends procedures for the operation of service water cooling systems.

Contrary to the above and as described below, on September 23, 1986, plant operations procedures associated with Engineering Safeguards Actuation System Testing (ESAS) were not properly implemented.

(1) Surveillance Procedure (SP) 1303-5.2, June 22, 1986, " Loading Sequence and Component Test and High Pressure Injection Logic Channel Test," Appendix 1, and Operating Procedure (0P) 1104-2, Revision 60, September 19, 1986, paragraph 3.9.2.B.7 require, in part, that cooling water supply valve DC-V-41A be open when shifting the "1A" makeup pump to "ES" standby.

Contrary to the above, DC-V-41A was not opened when shifting the "1A" makeup pump to ES standby lineup. As a result, this pump had no cooling water available for about eighteen hours.

(2) SP 1303-5.2, Appendix 1, and OP 1104-2, paragraph 3.9.2.B.7 require, in part, that cooling water supply valves for the "1A" makeup pump be independently verified in their correct position, upon shifting the "1A" makeup pump to ES standby.

Contrary to the above, during the "1A" makeup pump shift to ES standby, cooling water supply valves were not independently verified to be in their correct position.

(3) Administrative Procedure (AP) 1001G, " Procedure Utilization,"

paragraph 3.3.5a, states, in part, " surveillance procedures require rigorous attention in carrying the procedure steps in detail." In addition, AP 1001J, " Technical Specification Surveillance Testing Program," paragraph 3.2.4, states, in part, that "unless specifically excluded by the surveillance procedure, test steps shall be performed in the order specified." SP 1303-5.2, Revision 22, dated June 11, 1986, OFFICIAL RECORD COPY IR TMIl 86 0005.0.0 8701090557 - 12/31/86 PDR 231 O ADOCK 05000289 PDR

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Appendix A 2

" Loading Sequence and Component Test and High Pressure Injection Logic Channel Test," paragraph 5.9, states, in part, "during the performance of this procedure, the individual performing the evaluation shall sign off each step of the procedure as it is accomplished."

Contrary to the above, the performance of the initial steps of Surveillance Procedure (SP) 1303-5.2 were accomplished by the instructions stated in the Plant Operations Director Night Order Book; and, as a consequence, the steps of SP 1303-5.2 were not performed and signed off in the order prescribed in the surveillance procedure.

This represents a Severity Level IV Violation (Supplement I).

B. The 10 CFR 50 Appendix B Criterion 3 and the licensee's (NRC approved)

Quality Assurance Plan (QAP), Section 4.1 require, in part, that measures shall be established to assure that applicable design basis for those structures, systems, and components to which the appendix applies are correctly translated into specifications, drawings, procedures, and instructions.

1. The 10 CFR 50 Appendix A Criterion 4 requires, in part, that structures important to safety be designed to accommodate the effects of and be compatible with the environmental conditions associated with postulated accident conditions and that these structures shall be appropriately protected against dynamic effects such as missiles that may result from events and conditions outside the nuclear power unit. The updated Final Safety Analysis Report (July 1982), Section 5.1.3 and Figure 5.1-1, provides as a design basis that the reactor building (RB) is a structure designed to aircraft impact criteria and it indicates that the RB equipment hatch is to be protected by a missile barrier.

Contrary to the above, between April 23-28, 1986, the reactor building equipment hatch was not protected by a missile barrier in that the associated protection door was open; i.e., not positioned in front of the hatch. Further, as of October 3, 1986, no measures existed to assure that the design basis aircraft protection (RB equipment missile door) is shut during reactor startup and power operations.

2. The QAP Appendix C commits to the implementation of Regulatory Guide

, 1.64, Revision 2, June 1976, and ANSI N45.2.11, 1974, on " Quality Assurance Requirements for the Design of Nuclear Power Plants." ANSI N45.2.11, paragraph 4.2, requires, in part that applicable design inputs and basis be identified in sufficient detail and documented.

OFFICIAL RECORD COPY IR TMIl 86 0005.1.0 12/31/86

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! O Appendix A 3 Contrary to the above, as of October 3, 1986, the design basis was not documented in sufficient detail for radiation monitor setpoints for RM-G16 through RM-G21 and RM-L1, in which the function is to isolate certain reactor building penetrations. No correlation was documented between pipe radioactivity concentration and radiation area readings detected by the monitors.

This is a Severity IV Level Violation (Supplement I).

C. The 10 CFR 50. 59(b) states, in part, that, "... Licensee ... records

[of changes in the facility or procedures as described in the safety analysis report] shall include a written safety evaluation which provides the basis for the determination that the change ... does not involve an unreviewed safety question...."

AP 1021, Revision 1, dated November 27, 1985, " Plant Engineering Modifications," paragraph 3.2.2, defines requirements for documented records, in part, as evaluations required in support of design documents including safety analysis described in EP-016. Technical Functions (TF) Procedures EP-016, Revision 1-00, dated January 18, 1985, " Nuclear Safety / Environmental Impact Evaluation," Exhibit 3, paragraph 3.3, requires, in part, the written safety evaluations for facility changes describe how the proposed changa will or will not affect the safety functions by addressing concerns such as system performance (3.3.1).

Contrary to the above, between April 21 and April 22, 1986, prior to and during the reactor coolant system (RCS) deboration to criticali-ty activity, one of two channels of source range instrumentation (NI-1) was made inoperable by changing the high voltage power supply cable connection at reactor building penetration No. 202E without a proper evaluation on system performance.

This is a Severity Level IV Violation (Supplement I).

Pursuant to the provision of 10 CFR 2.201, GPU Nuclear Corporation is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and, (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given in extending this response time.

OFFICIAL RECORD COPY IR TMIl 86 0006.0.0 12/31/86

.,- . Operations 18 50-289 TMI-1 Hearing Service List t

Sheldon J. Wolfe, Chairman Bruce W. Churchill, Esquire Administrative Judge Shaw, Pittman, Potts & Trowbridge Atomic Safety & Licensing Board Panel 2300 N Street, N.W.

U.S. Nuclear Regulatory Commission Washington, D.C. 20037 Washington, D.C. 20555 Dr. Oscar H. Paris Atomic Safety & Licensing Board Administrative Judge Panel Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Frederick J. Shon Atomic Safety & Licensing Appeal Administrative Judge Board Panel Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Joanne Doroshow, Esquire Docketing & Service Section Three Mile Island Alert, Inc. Office of the Secretary 315 Peffer Street U.S. Nuclear Regulatory Commission Harrrisburg, PA 17102 Washington, D.C. 20555 Louise Bradford Mary E. Wagner, Esquire 1011 Green Street Office of Executive Legal Director Harrisburg, PA 17102 U.S. Nuclear Regulatory Commission Washington, DC 20555 Thomas Y. Au Assistant Counsel Commonwealth of Pennsylvania Dept. of Environmental Resources Bureau of Environmental Resources Room 505, Executive House P. O. Box 2357 Harrisburg, PA 17120

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