ML20217P708
| ML20217P708 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/01/1998 |
| From: | Marilyn Evans NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Langenbach J GENERAL PUBLIC UTILITIES CORP. |
| References | |
| 50-289-97-09, 50-289-97-9, EA-97-533, NUDOCS 9805070032 | |
| Download: ML20217P708 (2) | |
See also: IR 05000289/1997009
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May 1,1998
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Mr. J. Langenbach
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' Vice President and Director
Three Mile Island
GPU Nuclear, Inc.
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Route 441 South
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P. O. Box 480
Middletown, PA. 17057-0480
SUBJECT: -
NRC INTEGRATED INSPECTION NO. 50-289/97-09 (EA 97-533)
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Dear Mr. Langenbach:
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This letter refers to your February 26,1998, correspondence, in response to our
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January 27,1998, letter.
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Thank you for informing us of the corrective and preventive actions regarding Violations
EA 97-533 (01013) and EA 97-533 (03014) documented in your letter. These actions will
be examined during a future inspection of your licensed program,
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- Your cooperation with us is appreciated.
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Sincerely,
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Original Signed By:
Michele G. Evans, Chief
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Project Branch No. 7
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Division of Reactor Projects
Docket No. 50-289
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cc (w/o cv of Licensas Resoonse Lattari:
J. C. Fornicola, Director, Nuclear Safety Assessment
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M. J. Ross, Director, Operations and Maintenance
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J. Wetmore, Manager, TMI Nuclear Safety and Licensing
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cc tw/cv of Licensas Resnonsa Latterh
TMI-Alert (TMIA)
E. L. Blake, Shaw, Pittman, Potts and Trowbridge (Legal Counsel for GPUN)
Commonwealth of Pennsylvania
9905070032 990501
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ADOCK 05000299
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- Mr. J. Langenbach
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' Distribution (w/cv of Licensee Response Letter):
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Region i Docket Room (with concurrences)-
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' Nuclear Safety Information Center (NSIC)
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' PUBL!C
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NRC Resident inspector .
M. Evans, DRP
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N. Perry, DRP
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- D. Haverkamp, DRP
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A. Linde, DRP -
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J. Yerokun, DRS
B. McCabe, EDO
C. Thomas, NRR
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. T.'Colburn, NRR
R. Correia, NRR
F. Talbot, NRR
inspection Program Branch, NRR (IPAS)
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' DOCUMENT NAME: G:\\ BRANCH 7\\TM19709. REP
' . Ta secohn a copy of this " 1/ Indicate in the box: *C" = Copy without attachment / enclosure T = Copy with attschment/ enclosure
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DATE
04/29/98
04/Ji /98
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04/
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0FFICIAL RECORD COPY
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GPU Nuclear. Inc.
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floute 441 soum
NUCLEAR
Post ovvice son 400
Middletown, PA 1757 0400
Tel717 944-7621
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February 26, 1998
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 Notice of Violation (NOV) dated January 27,1998
The attachment to this letter transmits the GPU Nuclear (GPUN) Inc. responses to Violations I
and III contained in the NOV referenced above. On February 20,1998, GPUN received verbal
approval to combine the response to Violation II with the response to the violation anticipated in
Inspection Report 97-10, which is of a similar nature and involves concerns regarding procedural
compliance.
Violations I and III identified in the NOV are addressed
arately to include: (1) the reason for
. 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 this event.
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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
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Engineer, at TMI phone No. (717) 948-8753.
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Sincerely,
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' James W. Langenbach
Vice President and Director, TMI
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Attachment
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Page 2 of 2
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I, James W. Langenbach being duly sworn, state that I am the TMI Vice President and an Officer
of GPU Nuclear, Inc. and that I am duly authorized to execute and file this response on behalf of
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GPU Nuclear. To the best of my kndwledge and belief, the statements contained in this document
are true and correct. To the extent that these statements are not based on my personal knowledge,
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they are bas'ed 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. Langenbach
Vice President, TMI
GPU Nuclear, Inc.
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cc:
NRC Administrator Region I
TMI Senior Resident Inspector
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TMI Project Manager
File 97105
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ATTACIIMENT
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RESPONSE TO NOTICE OF VIOLATION
January 27,1998
IR 50-289/97-09
EA 97-533
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1.
Technical Specification 4.2.2 requires that in service testing (IST) of ASME Code Class
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1, Class 2, and Class 3 valves shall be performed in accordance with Section XI of the
ASME Boiler and Pressure Vessel Code (ASME Code). The ASME Code and OMa-
1988, Part-10, paragraph 3.4, requires that, when a valve or its control system has been
replaced, an in-service test must be performed prior to returning the valve to service.
Contrary to the above, on October 31,1995, the pressurizer power operated relief valve
(PORV), a Class I valve, was returned to service without performing an IST to verify
proper valve operation after the PORV was replaced. As a result, a wiring error, that
prevented the PORV from opening in response to an automatic or manual signal, was not
detected. Consequently, the PORV was inoperable for the operating cycle from October,
1995, until September,1997,
GPUN Resoonse:
1.
Reasons for Violation
During the PORV reinstallation in the 11R refueling outage, the power supply leads to
the valve solenoid were improperly landed. The error went undiscovered for a number of
reasons which were determined to be the root cadses of the event, including: (a) less than
adequate self-checking on the part of the technician who reinstalled the valve; (b) less
than adequate independent verification by the inspector checking the work; and (c) failure
to perform the required post-maintenance test (PMT) pursuant to the Technical Specification 4.2.2 IST requirement. The failure to perform the required PMT was due to
less than adequate procedural structure, content, and usage and incomplete guidance in
the Job Order package to direct the performance of a PMT. In addition, insuflicient
detail on the installation procedure design drawing was a contributing factor to the causes
of this event occurrence, Also, it has been determined that a programmatic weakness
existed in the verification of the performance of PMTs specified on Job Orders.
2.
Corrective steps taken and results achieved.
a.
The PORV was replaced during the 12R refueling outage, wired correctly, and a
proper Post Maintenance Test was performed pursuant to the surveillance
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requirements of Technical Specification 4.2.2. Full compliance was achieved
prior to start-up and returning to full power operation.
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GPUN Response to Violation I (continued)
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b.
The individuals involved in the 11R installation and independent verification were
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provided with direct coaching which critically examined the self-checking
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technique used by the technician and the examination technique of the
independent verifier to improve the applicable work processes. This coaching
was provided to the individuals involved during December,1997. Additionally,
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the concepts of havin'g a questioning attitude, self-checking and "Be Sure" were
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emphasized by the Plant Maintenance Director during scheduled shop meetings.
3.
Corrective steps to be taken to avoid further violations.
The requirement to perform a Post Maintenance Test for this activity (PORV
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replacement each refueling outage) will be clarified through procedural changes
and appending of the vendor manual diagrams, which depict with greater clarity
the correct wiring configuration, as well as a reduction or elimination of cross-
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referencing and branching. Completion ose: March 31,1998.
~ i) The department, which is responsible for Job Order package closure (s), has
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been tasked with the development of programmatic improvements to reduce the
possibility of a missed PMT from occurring, following a study of how the
requirements for PMTs of components and systems are controlled. Completion
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date: March 31,1998. (ii) Implementation of recommended programmatic
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improvements will be based on the results of the aforementioned study.
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Completion date: June 30,1998.
4.
Dates of full comoliance.
Pursuant to the GPUN commitments contained in LER 97-0.10 full compliance with the
corrective actions above will be achieved on or before June 30,1998. Full compliance
with Technical Specification 4.22 requirements was achieved prior to restart from the
12R refueling outage,
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III.
Technical Specification 6.11, Radiation Protection Program, requires that procedures for
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personnel radiation protection shall be prepared consistent with the requirements of 10 CFR 20 and shall be approved, maintain ed, and adhered to for all operations involving
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personnel radiation exposure.
10 CFR 20.1501 requires that each licensee shall make or cause to be made, surveys that
may be necessary for the licensee to comply with the regulations in 10 CFR 20 and are
reasonable under the circumstances to evaluate the extent of radiation levels,
concentrations or quantities of radioactive material, and the potential radiological hazards
that could be present.
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Notice of Violation III(continu~n
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Contrary to the above, as of October 4,1997, the licensee's hot particle control procedure,
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- Procedure 6610-ADM-4110.04, was inconsistent with 10 CFR 20.1501, in that it did not
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- cause surveys to be made to assure compliance with 10 CFR 20.1201(a)(2)(ii), which
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limits radiation exposure to the skin. Specifically, the procedure did not provide
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. sufficient direction to assure that surveys to verify elimination of hot panicles following
decontamination of newly exhosed surfaces upon raising the reactor vessel seal plate,
were adequate to evaluate the potential radiation hazards.
As a result, the hot panicles were not sufficiently removed such that the area did not
require hot panicle controls, nor were hot panicle controls established. Consequently,
due to a hot panicle, a radiation worker received a skin exposure of approximately 14
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REM, 30% of the 10 CFR 20.1201 annual limit of 50 REM.
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GPUN Response:
1.
Reasons for Violation
Due to procedural weaknesses, required actions to be taken in the event of emergent hot
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panicles were not taken and as a result the conduct of this task was less than adequate.
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Following draindown of the fuel transfer canal, it was cleaned and released from hot
particle controls. The reactor vessd lui eal plate was to be lifted and parked. A pre-
job discussion was conducted between the Rad Con Technician (RCT) and the work
crew. However, upon raising of the seal plate numerous hot panicles were discovered by
the RCT. The work effort was reorganized and the RCT directed removal of hot particles
from the area without formally re-establishing hot particle controls and without notifying
Rad Con supervision.
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2.
Corrective steps taken and results achieved.
a.
All ALARA Reviews and Radiation Work Permits (RWPs) were reviewed for
ambiguous hot panicle control requirements. No additional problems were
identified.
b.
The hot particle controls program was revised to address weaknesses relative to
the classification of emergent hot panicle areas, supeivisory notifications, and
improved monitoring requirements.
3.
Corrective steos to be taken to avoid further violations.
It is expected that the corrective actions taken above will preclude further violations from
occurring.
4.
Dates of full compliance:
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Corrective actions 2.a and 2.b have been completed and procedural consistency with
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NRC regulations has been achieved.
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