ML20214K304
| ML20214K304 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/11/1986 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 5211-86-2135, NUDOCS 8608210024 | |
| Download: ML20214K304 (6) | |
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GPU Nuclear Corporation Nuclear
- eme:reo o
s Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:
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August 11, 1986 5211-86-2135 Dr. Thomas E. Murley Region I, Regional Administrator U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Dr. Murley:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Response to Notice of Violation and Notice of Deviation on Inspection Report 86-06 Attached is the GPUN response to Appendix A and B of Inspection Report No.
50-289/86-06 " Notice of Violation" and " Notice of Deviation."
Si ncerely,
. D.
u il Vice President & Director, TMI-1 HDH/DVH/spb:0639 A cc:
R. Conte Sworn and subscribgd to before me this //f* day of
/l u d
,1986.
8609210024 860011 PDR ADOCK 05000289 kam A Aumu NAkV PUSUC SI
. R0 MIDU!ETCWN BORO. DAUPHIN COUNTY EY C0;At!!SION LXPIRf1 JUNE 12.1989 Nember, Pennsylvama Association of Notaries GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation 7e O t I
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ATTACMENT 1 As a result of an inspection conducted between April 11 and May 16,1986, and lin accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the following violation (s) and deviation were identified.
VIOLATION A, ITEM 1-Alarm response Procedure C-2-1, Revision 15, dated February 24, 1986, for "RM-A-7 Gas Waste Tank Discharge" monitor paragraph " Manual Actions Required" required,.in part, that, on first alarm (alert), the waste gas release be stopped by closing WDG-V-47, Discharge Isolation Valve, and that radiological controls department sample the system.
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Contrary to the above, between 12:45 p.m. and 8:30 p.m. on April 19, 1986,.a gas waste tank discharge release occurred with RM-A-7 in first alarm (alert) with no action to stop the release and have radiological controls department sample the system.
RESPONSE TO VIOLATION A, ITEM 1 On April 19, 1986 waste gas release G86-04042 was commenced releasing WDG-T-1C to the suction of the AH-E-14 fans and ultimately the station vent. The 1
monitored pathway consisted of RM-A-7G and RM-A-8 radiation monitoring j
devices. The release was performed in accordance with the applicable section of Procedure OP 1104-27 Waste Gas System and the release permit paperwork.
l The release paperwork actions stated the maximum " estimated" reading (RMS counts) to be 1.777E04. The release yielded a high reading of 2.5E04 with the RM-A-7G alert setpoint set at 2E04 cps.
There was no corresponding alarm condition on the monitored station vent pathway RM-A-8.
The Shif t Supervisor (SS) reviewed Procedure C-2-1 Radiation Level Hi Alarm Response, and RM-A-7 alarm response. The SS understood the ALERT setpoint was set to assure i
evaluation of the possible high radiation levels.
Based upon the observed steady reading of RM-A-7G and RM-A-8 at levels well within limits and no other i
abnormal-symptoms the SS decided the isolation called for in the alarm response procedure action did not have to be applied. The decision was based on a specific assessment of the basis and the intent of the ALERT alarm, the reason for the respective actions and the observed steady trend on RM-A-7 gas j
channel with no adverse affect at the station vent and ultimately the public.
l The SS actions were in accordance with Procedure AP 100lG-Procedure 1
Utilization, concerning alarm response implementation. That is the reason for arbitrarily setting the alert setpoint as a function of the high alarm setpoint (ie.10% of high alarm, etc.). The ALERT alarm is a warning to assure consideration of possible adverse trends with potential adverse impact on station personnel or the public.
This was not the case for this event.
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I The SS i
We conclude there was not a failure to adhere to approved procedures.
followed the guidance in the administrative procedure. The alarm response was subject to evaluation by the Shif t Supervisor due to the predicted high RMS l
counts for this release. The decision was to not invoke the alarm response l
following review of the required parameters. AP 100lG states " Response to alarm procedures shall be followed to the ~ degree appropriate. Due to the wide variety of responses and the varying degrees of detail in these procedures, the need to consult the procedure depends on the nature of the alarm.".In particular, alarm responses are subject to evaluation using supportive
-parameters to confirm whether an abnormal situation warranting any necessary.
action exists. Alarm responses are then invoked to the degree appropriate by 1
qualified personnel upon confirming such action is warranted.
In this case i
the action called for in the alarm response procedure was not appropriate.
The apparent violation was a proper response as' allowed by the GPUN l
Administrative Procedures. A revision to the subject alarm response procedure-l and a revised monitor setpoint eliminates the need to interpret possible similar occurrences and make the intent and actions more clear.
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NOTICE OF VIOLATION A, ITEM 2 Administrative Procedure 1029, Revision 21, April 22,1986, " Conduct of Operations," paragraph 5.7.b, states that "a minimum of 1 SR0 (Senior Reactor i
Operator) and 1 R0 (Reactor Operator) must be in the control room at all times when the RCS (Reactor Coolant System) is greater than 2000F.
Contrary to the above, between approximately 12:15 a.m. and 12:35 a.m.. on April. 21,1986, an SRO was not in the control room at all times with the RCS 4
greater than 2000F, j
RESPONSE TO VIOLATION A, ITEM 2 As stated in section 2.2.4 of Inspection Report 50-289/86-06, an on-duty SR0 was not in the control room for 20 minutes, however during that period of time a just relieved SR0 was in the control room for all but approximately two i
minutes. When the on-duty SRO lef t the control room, he did not announce to t
the other SR0 that he was leaving and therefore the relieved SRO was not aware that he needed to stay in the control room. During these two minutes.the l
relieved SRO was either in the Shift Supervisor's Office or adjacent I & C shop. As recognized by the inspection report, management action was taken to ensure this oversight would not happen again. Corrective measures have been applied to ensure the letter of AP 1029 is satisfied.
The corrective actions included a confidential letter to each Shift Supervisor signed by the Director of TMI-1 which reinforced shift control and i
communications. As a follow-up to this memo, the Director of TMI-l met with each Shift Supervisor to discuss and ensure thorough understanding of the l
issues discussed in the confidential memo.
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NOTICE OF VIOLATION A, ITEM 3 Operating Procedure 1104-29E, Revision 19, dated March 20,1986, " Bleed and Feed Process," paragraph 12.2.5.h, for completion of bleed and feed cleanup of the Reactor Coolant. (RC) System, requires that WDL-V-164, "A" RC Bleed Tank
. Transfer Pump Suction Isolation Valve, be opened.
Contrary to the above, on April 21-22, 1986, between completion of bleed and I
feed cleanup for the reactor coolint system and prior to the start of deboration for criticality, WDL-V-164 was not opened.
[As a result, several attempts' by operators to start deborating (The RCS for reactor criticality) using the "A" RCBT resulted in successive transfer pump trips due to low suction pressure with the suction isolation valve closed.]
RESPONSE TO VIOLATION A, ITEM 3 During _ the 3-11 shif t on April 21, 1986 the bleed and feed (Daisey Chain) cleanup of the RCS was terminated. This cleanup was being performed per Operating Procedure 1104-29E section 12.0. The cleanup of the RCS had been performed in preparation of plant startup following the SM Eddy Current Outage. Due to the number of tasks associated with plant startup, one CR0 was assigned to take charge of securing the cleanup while another CR0 was assigned to the task of preparing to commence deboration of the RCS. The deboration of the RCS is performed per 1104-29E section 6.0.
This procedure (1104-29E) is written such that each section can stand as its own separate procedure. The CR0 who was performing section 6.0 was not aware that the other CR0 performing section 12.0 had not yet had WDL-V-164 opened. The CR0 who was performing section 12.0 dispatched an A0 to open up WDL-V-164 and the CR0 removed the Do Not Operate (DN0) tag from the control switch while he was waiting for the
' Auxiliary Operator to call back and confirm WDL-V-164 was open.
The only step in section 6.0 which referred to performing a complete valve line-up verification was step 6.2.8 which was a generic step stating "A current valve line-up exists per OP 1104-29". The operator verified this current valve line-up existed and then continued on with section 6.0.
The CR0 who was completing section 6 tried to commence deboration using the "A" RCBT but no flow could be established. After shift turnover the 11-7 shif t CR0 who was performing section 12.0 realized that if WDL-V-164 was still j
closed it was causing the problem for the CR0 performing section 6.0.
The A0 was called and he informed the CR0s that he was just entering the room in preparation to open WDL-V-164. The valve was then opened and the deboration was then commenced with no further problems. The operators did not consider this to be a significant event considering all the work involved with starting up the unit and therefore did not log this in their log books.
l This event resulted from a communications / coordination problem.
It is a routine practice during plant startup to have several tasks occurring simultaneously.
The applicable procedures were being followed for both the termination of the cleanup and the initiation of the deboration. The effect that these two procedure sections had on each other was not immediately j
recognized by the operating crews. This is what lead to the brief period of i
time that deboration flow could not be established.
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1 As a followup to this incident each of the operating crews will be briefed on 1
. the following items:
The need 'to better coordinate multiple tasks which are being a.
performed simultaneously.
b.
The need for better communication between personnel who are performing multiple tasks simultaneously in order to identify potential conflicts.
c.
The need to provide log book documentation of all off normal situations which occur during the performance of routine plant -
evolutions, s
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Shift management personnel will be br.iefed to ensure the pace of activities during major evolutions is not rushed and controlled at a level to prevent occurrences such as this.
These briefings will be completed by September 15, 1986.
DEVIATION B IE Bulletin No. 79-19 states that licensees should " provide training and periodic retraining in the Department of Transportation (DOT) and NRC regulatory requirements, waste burial license requirements and in your [the licensee's] instructions and operating procedures for all personnel involved in the transfer, packaging and transport of radioactive material...."
Licensee response to IE Bulletin No. 79-19, dated October 8,1979, stated that a training / retraining program to meet this requirement is expected to begin on November 19, 1979.
In addition, facility Procedure No. 6210-ADM-2622.01,
" Radioactive Waste Supenisor Training Program Units 1 and 2," requires biennial (every 2 years) retraining for Radioactive Waste Supervisors.
Contrary to the above, as of April 18, 1986, one supenisor was not trained within the last two years. His last training in the D0T and NRC regulatory requirements, waste burial license requirements, and procedures was conducted on January 26, 1982.
RESPONSE TO DEVIATION B As stated in the deviation, one supervisor was not trained in the last two years. This supervisor has sinca successfully completed this training on May 9, 1986.
No other supenisor was found to be outside the biennial retraining requirements.
In order to avoid further deviations in this area, GPUN will revise Procedure 6210-ADM-2622.01, " Radioactive Waste Supervisor Training Program, Units 1 and 2," to require that the Supenisor, Waste Disposal be notified in writing at the beginning of each quarter of all personnel who will reach their biennial retraining requirement during that quarter. The Supenisor, Waste Disposal will then ensure the retraining is scheduled and completed.
This procedure will be revised by September 1,1986.
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