ML20244A828

Forwards Response to IE Insp Rept 50-289/74-35 Re Apparent Violations Including Failure to Reduce Tilt Below Required Level or to Reduce Reactor Power/Imbalance Trip Setpoints within Specified Time Limit.Ref Nonroutine Rept 74-06

ML20244A828
Person / Time
Site:	Three Mile Island
Issue date:	01/30/1975
From:	Creitz W METROPOLITAN EDISON CO.
To:	Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20244A827	List: IR 05000289/1974035 ML20244A828
References
GQL-0710, GQL-710, NUDOCS 7911150563
Download: ML20244A828 (3)

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METROPOLITAN EDISON COMPANY sues:DIA R Y OF GENERAL. PUBUC UTIU TIES CORPORA TION

ST GFFICE BOX 542 RE ADING, PENNSYLVANIA A 19603 TELEPHONE 215 - 929-3601 JAN 3 01975 -

GQL 0710 Mr. Eldon J. Brunner, Chief ,

Reactor Operations Branch Directorate of Regulatory Operations - Region 1 U.S. Atomic Energy Commission -

631 Park Avenue King of Prussia, PA 19405

Dear Mr. Brunner:

Docket No. 50-289 NN Operating License No. DPR-50 Inspection Report 74-35 This letter and the attached enclosure are in response to your inspection report letter of Janucry 3,1975, concerning Mr. Spessard's inspection of the Three Mile Island Nuclear Station, Unit 1, and the findings thereof.

In response to apparent violation 1 and your request to be informed as to what specific limiting cond,ition for operation had been violated, please note that we have determined that the event as described in the inspection report constituted exceeding a limiting condition for operation as defined by Technical Specification 3.5.2.4.b.1. Further, we have determined that this event represented an Abnormal Occurrence as defined by Technical Specification 1.8b, but trust that the information contained in the Non-Routine Leport 74-06 letter dated November 29, 1974, toge the r with this submittal, satisfactorily addresses any concerns you may have had.

Since rely 9

///kY' W. M. reitz President WMC:RSB :cas Encl.: Response to Description of Apparent Violation

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File: 20.1.1/7.7.3.2.1 c//// f o d D

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. i ENCLOSURE Metropolitan Edison Company (Met-Ed)

Three FEle Island Nuclear Station Unit 1 (TMI-1) ,

Operating License No. DPR-50 Docket No. 50-289 Inspection No. 50-289/74-35 Apparent Violation 1 ,

l Technical Specification 3.5.2.4.b.1 states in part: '71 thin a period of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the quadrant power tilt shall be reduced to sess than 4 percent. . . ,

or the following adjustments in setpoints and limits shall be made:

1. The protection system reactor power / imbalance envelope trip setpoints s shall be reduced 2 percent in power for each 1 percent tilt."

10 CFR 50.36(c) (2) states in part: "When a limiting condition for operation of a nucicar reactor is not met, the licensee shall shut down the reactor ppq3pg or follow any remedial action permitted by the technical specification until the condition can be met."

Contrary to' the above, facility records indicated that following the dropped rod occurrence on November 17, 1974, which produced a quadrant power tilt in excess of 4 percent, the tilt was not reduced below the required limit or the reactor power / imbalance trip setpoints were not reduced to the required setpoint within the required period of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Actual trip setpoint adjustments for the 4 channels were accomplished over a period of about 6-10 hours following the existence of the excessive tilt condition. Additionally, when Technical Specification 3.5.2.4.b.1 (a limiting condition for operation) could not be met, the reactor was not shutdown in a time period commensurate with the above requirements, i.e., af ter reducing trip setpoints to the extent capable by design, but which were still in excess of the required limit, reactor operation continued for about 5.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> before a shutdown was initiated. (Nonroutine Repo rt 74-06, Telegram to RO:I dated November 18, 1974, and tht-Ed letter dated November 29, 1974).

Response

a. As a corrective action, the Reactor Protection System will be modified to extend the present range of the Power / Imbalance envelope trip setpoints to ensure compliance with Technical Specification 3.5.2.4.b.1 in the event of a tilt up to 25%.

b. As a preventative action, all responsible management and Shif t Supervisors will be instructed regarding 10 CFR 50.36 (c) (2).

In additica, OP 1102-4, Power Operation, will be revised to include a precaution regarding the requirements of 10 CFR 50.36 (c) (2) .

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c cl , Nith-regard to when compliance will .be achieved:-

K (1)' The modification 1to the Reactor Protection System will be '

inst'alled by June ,1975. -

(2) : Personnel will be' instructed 'and OP 1102-4 will be revised '

by' February 7,1975.

~ Apparent Violation 2' .

Technical Specification 6.7.2.a.4 states: " Events requiring notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone or telegraph to the Director of Regulatory Operations, Region I, followed by a wrioten report.within 10 days to the Director, Directorate of. Licensing, USAEC, Washington, D.C. 20545; with a copy to the Director 'of the Regional Regulatory Operations Office, shall ,

' include :

4.1 Incidents or Leonditions'which prevented or could have prevented the performance of the intended safety function of an engineered safety feature er of the. reactor protection system,"

Contrary to the above, the' premature tripping of the IB Engineered Safe-guards Motor Control Center feeder breaker due to a' faulty overcurrent trip device, which 'was corrected by Work Request No. 5213 completed on November 6,1974, was not reported to the AEC, as required.

We note that' subsequent to this inspection, .you reported -this occurrence as A0 74-26 (Telegram to RO:I dated December 2,1974, and tbt-Ed letter

, dated December 10, 1974'.)

Response -

a. It should be noted that the premature tripping of the 1B Engineered Safeguards Motor Control Center feeder breaker was reviewed by 'the Plant' Operating Review Committee (PORC) and the details of this

. review appear in PORC Minutes #246. The PORC did not consider this to be a reportable item at the time of review. Further, Station Managemect' concurred with PORC's findings, therefore, the required report was not initiated at that time. As a corrective action, the event was reported as Abnormal Occurrence A0 74-26 (Telegram to RO:1 dated December 2,1974, and >kt-Ed letter to D.O.L.. dated December 10, 1974),

b.- As a preventative action, the Station Superintendent has been counseled regarding what constitutes 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reportabic events, and' the Station Superintendent has in turn counseled the Unit' 1

. Superintendent and the PORC.

c.- The above actions have been completed, and full compliance has been achieved.

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