ML20236N702
| ML20236N702 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/31/1987 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 5211-87-2149, NUDOCS 8708120070 | |
| Download: ML20236N702 (4) | |
Text
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'E-Nuclear
- ,ome:reo 1
GPU Nuclear Corporation s
Middletown, Pennsylvania 17057 o191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:
July 31, 1987 5211-87-2149 Mr. William T. Russell Region I, Regional Administrator US Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Russell:
Three Mile Island Nuclear Station Unit 1 (TMI-1)
Operating License No. DPR-50 l
Docket No. 50-289 Notice of Violation Response for l
Inspection Report 87-09 (Corrected Copy)
This is a corrected copy of GPUN's response to the Notice of Violation for Inspection Report No. 50-289/87-09, dated July 23, 1987. Attachment A to this letter is GPUN's response to the subject Notice of Violation.
This letter is being resubmitted as a result of an error in the cover letter which forwarded that response where the inspection report number was r
referenced incorrectly.
Please disregard the earlier letter.
Sincerely, i
n H. D.
kill Vice President & Director, TMI-1 HDH/MRK/spb:0949A cc:
R. Conte G. Edison Document Control Desk Attachment Sworn and subscribed to before me this 3 / JE day swr P. LAO.,507ASV FWMC IMMETOW B0l10. DAUPlim COMTf b@ /*
EY Commt,31nti DWicts JilriE IL 1989 uember, Pr,r,rgterrit ASH &ths of Rcteeles
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Notary Pi(blic GPil Nuclear Corporation is a subsidiary of the General Public Utilities Corporation B708120070 870731 DR ADOCK 0500 9
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ATTACHMENT A FINDING:
A.
Code of Federal Regulations Title 10, Part 50, Appendix B, Criterion III, and the licensee's (NRC approved) Operational Quality Assurance Plan, Sections 4.1, 4.2.8, and 4.2.9 require, in part, that measures shall be established and documented to assure that the applicable specified design.
requirements, such as design bases, regulatory requirements, codes and standards, are correctly translated into specifications, drawings, o
procedures, or instructions.
Further, design verification methods shall be established to verify design documents, subject to procedural control, and include specifications and calculations.
Contrary to the above, as of March 19, 1987, design modification WA A25A-53182, Pressurizer Platform Installation, did not adequately incorporate thermal expansion of the pressurizer, and subsequent licensee verifications did not identify the error.
With the pressurizer hot at 50 psig, the subject platform was in contact with the pressurizer spray line.
This is a Severity Level IV violation (Supplement 1).
RESPONSE TO VIOLATION A:
The TMI-1 pressurizer was reinsulated during the 6R Outage to reduce heat losses into the containment.
Part of this work entailed modification of the work platform on top of the pressurizer to ensure compatibility with the new insulation system and to facilitate maintenance in this area.
During heatup for restart, one edge of this platform was found to be bearing against the pressurizer spray line.
The insulation system for the pressurizer was procured and installed in accordance with the requirements of GPUN Specification SP 1101-32-022, Technical Specification for Nuclear Grade Insulation Systems; TMI-l Reactor Building. This is a generic specification for all insulation in the TMI-l Reactor Building.
During the preparation of this specification, it was realized that to obtain the same insulating properties, the replacement insulation would be thinner than the existing panels and thinner panels would be bounded by the envelope from the existing panels. The possibility of an appurtenance or secondary effect from these panels was not adequately addressed.
The design verification program does require verification of design parameters (i.e. pressure, temperature, seismic, heat, dynaaic, etc.) and in fact thermal expansion was addressed. There were areas of thermal expansion interferences identified and corrected, however this interference was not previously identified.
(1) Corrective Steps Which Have Been Taken and Results Achieved:
This design error was evaluated and the interference removed prior to startup with no overstress evaluated to have occurred to the spray piping.
(2) Corrective Steps Which Will Be Taken to Avoid Further Violations:
I GPUN Specification SP 1101-32-022 is being revised to incorporate the necessary changes in order to avoid the problems which have been identified when procuring and installing insulation in the future.
l (3) Date When Full Compliance Will Be Achieved:
Revision of SP 1101-32-022 will be completed by October,1987.
Use of this specificatioli prior to this date is not anticipated.
FINDING:
B.
The 10 CFR 20.201(b) requires that each licensee make such surveys as may be necessary to comply with all sections of Part 20. As defined in 10 CFR 20,201(a), " survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions.
Contrary to the above, the licensee failed to perform an adequate survey (evaluation) of radiological hazards prior to worker entry to a letdown filter cubicle on March 7,1987.
Specifically, the licensee's evaluation was inadequate in that it did not recognize the high potential for generating airborne radioactivity resulting from (a) worker presence and traffic in the highly contaminated cubicle and (b) the passing of a prefilter through the highly contaminated cubicle overhead access holes.
Contamination levels on the cubicle floor and lining the overhead access holes ranged up to 40 mrad /hr and 240 israd/hr, respectively.
As a result, work performed in the makeup filter cubicle on March 7, 1987, generated airborne radioactivity resulting in the unplanned exposure to airborne radioactive material of several workers.
This is a Severity Level IV violation (Supplement IV).
RESPONSE TO VIOLATION B:
GPUN agrees that there was a failure to perform an adequate survey inside the Makeup Filter (MU-F2A/B) cubicle as intended by 10 CFR 20.201(b).
Failure to anticipate changing conditions relative to the filter mock-up work, failure to survey the access holes in the ceiling of the cubicle, and failure to evaluate the extent of floor and component contamination levels based on previous cubicle turvey history contributed to the inadequacy of the survey performed on March 7, 1987.
(1) Corrective Steps Which Have Been Taken and Results Achieved:
GPUN issued a memorandum (9100-87-0141) on April 2,1987 to all Group nad Con Supervisors at TMI-l re-emphasizing the need to anticipate changing radiological conditions due to work activity and the need for better dissemination of information related to problems that have been identified.
Further, through its content, this memo reinforces the need to perform appropriate evaluations in compliance with 10 CFR 20,201(b). _ _ - _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _
. \\,
Regarding the dose assessment of potentially exposed personnel, all of those directly involved in the activities of concern have been identified and MPC-hrs assigned. GPUN has taken action to determine if previous entries were made into the filter cubicle for other reasons.
One individual, a Rad Con Technician, was found to have made an entry on January 8,1987 to perform a radiological survey without the use of a respirator and an air sample survey was not taken. An evaluation was performed based on the air sample data from the March 7,1987 incident (50.1 MPCs).
Applying this data resulted in an estimated calculation of the internal intake of 5 MPC-hrs. This was documented in a GPUN meinorandum (9100-87-0215) dated May 12,1987, " Entry into Letdown Prefilter Cubicle."
All of the problem areas related to Makeup Filter changeouts, transfers, and subsequent disposal problems have been identified in a GPUN memorandum (9100-87-0131) entitled " Makeup Filter Chronology."
(2) Corrective Steps Which Will Be Taken to Avoid Further Violations:
In addition to the actions which have been taken, GPUN has identified additional long term actions related to the Makeup Filter System in order to improve associated work evolut1ons.
A meeting was held with the affected department managers in order to define the act'ons which need to be taken and plan the work. The list of long term actions is being evaluated for approval and will be provided separately.
(3) Date When Full Compliance Will Be Achieved:
GPUN believes that full compliance related to this violation has been achieved.