ML20199H595

Discusses Insp Rept 50-289/97-09 on 970907-1101 & Forwards NOV Re Inadequate post-maint Testing Following Replacement of Pressurizer Power Operated Relief Valve

ML20199H595
Person / Time
Site:	Crane
Issue date:	01/27/1998
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Langenbach J GENERAL PUBLIC UTILITIES CORP.
Shared Package
ML20199H600	List: ML20199H595 ML20199H614
References
50-289-97-09, 50-289-97-9, EA-97-533, NUDOCS 9802050082
Download: ML20199H595 (6)

See also: IR 05000289/1997009

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UNITEo STATES

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475 ALLENDALE ROAD

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January 27, 1998

EA 97 533

Mr. James Langenbach

Vice President and Director, TMl

GPU Nuclear Corporation

Three Mile Island Nuclear Station

Post Office Box 480

Middletown, Pennsylanla 17057 0191

SUBJECT:

NOTICE OF VIOLATION

(NRC Integrated Inspection Report No. 50 299/97 09)

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Dear Mr. Langenbach:

This refers to the inspection conducted between September 7,1997, and November 1,1997,

at the Three Mile Island Nuclear Station in Middletown, Pennsylvania, the findings of which

were discussed with members of your staff during an exit meeting on November 13,1997.

During the inspection, apparent violations were identified related to your activities during the

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refueling outage.

The inspection report addressing these issues was previously

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forwarded to you on December 2,1997.

On December 22, 1997, a predecisional

enforcement conference (conference) was ennducted with you and members of your staff, to

discuss the violations, their causes, and your corrective actions.

Based on the information developed during the inspection and the information that you

provided during the conference, three violations of NRC requirements are being cited and

are described in the enclosed Notice of Violation (Notice). The circumstances surrounding the

violations are described in detail in the subject inspection report. The violations involve: (1)

inadequate post maintenance testing following replacement of the pressurizer power operated

relies' valve (PORV), in October 1995, that resulted in failure to detect that the PORV actuation

circuit was miswired rendering the PORV inoperable; (2) failure to follow procedures when

filling the reactor coolant system (RCS) on October 5,1997, that resulted in an uncontrolled

spill of water from the control rod drive mechanism (CROM) vents; and (3) Inadequacies in

the procedure for the control of radioactive (hot) particles that resulted in a worker receiving

a significant skin exposure on October 4,1997.

The most significant violation involved the inoperable PORV. During rewiring of the PORV

actuation solenold, following replacement of the PORV during the 11R refueling outage in

October,1995, the terminal connections on the solenoid were not clearly marked.

Nonetheless, neither the technician who landed the leads, nor the technician that

independently vetified the wiring, stopped and positively determine the correct terminal

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locations. Instead, both technicians made incorrect assumptions as to the terminallocations.

As a result, the PORV was miswired and would not have opened in response to a manual or

automatic actuation signal.

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The failure to perform adequate post maintenance testing following replacement of the

pressurizer PORV resulted in this condition not being identified. Specifically, following the

incorrect wiring of its actuation solenold, no test was performed to ensure that the PORV

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would open in response to en automatic or manual actuation signal. This f ailure corstitutes

a violation of the Technical Specification (TS) requirement to perform in service testing. At

the conference, you indicated that the failure to perform the post maintenance test (PMT) was

due to procedural and work scheduling inadequacles. Specifically, no PMT checkoff was

provided in the PORV replacement and inspection procedures, and there was incomotete

guidance in the job order package to direct the performance of the PMT.

Tne inability to open the PORV would have prevented it from performing its pressure relief

function either during power operations or during low temperature conditions during heatup

and cooldown. Even though the pressurizer safety valves (the primary pressure relief system),

were available to provk'e overpressure protection during power operations, and administrative

controls were in place to provide low te nperature overpressure protection, the diversity

provided by the PORV for these functions was not available for the entire operating cycle, a

period of 23 months. Additionally, the PORV would not have been available to provide a bleed

path for high pressure injection (HPI) cooling or to depressurize the RCS to establish long term

decay heat removal following a steam generator tube rupture. The unavailability of tha PORV

for pressure relief or HPI cooling had potential conseqeences in that it resulted, as determined

by your own calculations, in a 16% increase in the TM! core damage frequency, if an event

occurred needing the PORV to be opened. This was preventable if requirements for post-

maintenance testing had been met. Therefore, the violation has been categorized at Severity

Level lli in accordance with the " General Statement of Policy and Procedure for 'NRC

Enforcement Actions" (Enforcement Policy), NUREG 1600.

In accordance with the Enforcement Policy, a base civil penalty in the amount of $50,000ls

considered for the Severity Level lil violation that occurred prior to November 12,1995.

Because your facility has been the subject of escalated enforcement actions within the last

2 years,' the NRC considered whether credit was warranted for / dent //ication and Correct /v6

Act/on in accordance with the civil penalty assessment process in Section VI.B.2 of the

Enforcement Policy. Credit was warranted for identification because your staff identified,

during the 12R refueling outage, that the PORV had been miswired and that nc PMT had been

performed following the 11R refueling outage. Credit was also warranted for corrective

actions because your actions were considered both prompt and compruhensive.

Those

actions included: (1) communication of management expectations for self-checking,

independent verification, and performance of post maintenance testing; (2) planned revisions

to the PORV maintenance procedure to clarify the FMT reqWrements, and to the job order

program to include the vendor manual wiring diagrams in the job order package; (3) review

of other work packages to ensure that all required PMTs had been performed; and (4) plans

to perform a process study to ivify and correct weaknesses in the PMT program,

e.g., A Notice of Violation and Pmposed Imposition of Civil Penalties in the amount of $210,000 was issued

on October 8.1997 (EAs 97 070. 97117,9,'-t27. and 97 256), for numerous violations related to several areas

of plant performance includicg engineering design controls, classification and environmental qualification of

components, corrective actions, and emergency preparedness.

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Therefore, to encourage prompt identification and comprehensive correction of violations, I

have been authorized, after consultation with the Director, Office of Enforcement, not to

propose a civil penalty in this case. However, significant violations in the future could result

in a civil permity.

With respect to the overfill of the RCS, the shift supervlsor (6S), who was supervising the fill

and vent of the 11CS in October,1997, believed that there was not enough water available in

the reactor coolant bleed tank (RCBT) to complete the intended evolution. Although the SS

appropriately consulted his supervisor and was told that there was sufficient water available

in the RCBT, the SS, still believing that there was insufficient water available, used an

inappropriate procedure to fill the RCS from the borated water storage tank (BWST). Other

control room operators did not que#on the SS's decision. Your staff failed to adhere to the

limitations provided in the decay heat removal (DHR) system operating procedure (OP) when

they used the DHR pumps to provide makeup to the RCS directly from the BWST during the

fill and vent of the RCS, Additionally, they failed to follow the RCS fill and vent procedure

when they failed to terminate the RCS fill at the required point.-- As a result, borated water -

spilled onto the reactor vowsel head and control rod drive (CRD) components, potentially

degrading those components and creating a radiclogical condition warranting remediation.

While this violation is classified at Severity Level IV given the significance of the occurrence,

it raises concerns regarding the questioning attitude of the staff and management's

expectations for adherence to procedures. At the aonference, you indicated that the problem

was that the SS failed to comply with normal work practices specified in your conclect of

ciperations administrative procedure (AP), rather than's failure to adhere to the RCS fill and

vent procedure or the DHR system operating procedure. The NRC is concerned that plant

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management may not be'providing a high. standard for procedure adherence and may be

providing operators with the impre,asion that it is acceptable to use procedures that were not

specifically prepared to support an activity.

Finally, with respect to the inadequate hot particle control procedure, an emergent hot particle

area was discovered during surveys of newly exposed surfaces upon raising the reactor vessel

heed seal plate following work in the fuel transfer canal in October,1997. Upon discovery

of these conditions, the radiation control technician (RCT) assigned to the job elected to

proceed without consulting supervision. Although the area was subsequently decontaminated,

the surveys that were performed f*>llowing the decontamination were not adequate to verify

the removal of the hot particles. Additionally, a hot particle control area was not formally

established. Your radiological protection (RP) procedure RP for hot particle controls was

inconsistent with 10 CFR 20.1501 in that it did not provide sufficient direction to assure that

adequate surveys were performed and that adequate hot particle controls were established.

- This constituted a violation of Technical Sp cification requirements for the radiation protection

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program which require that procedures for personnel radiation protection shall be prepared

consistent with the requirements _of -10 CFR 20. As a result of the inadequate surveys and

lack of sufficient hot particle controla, a worker received a calculated dose of approximately

14 rem to the skin. While the violation is classified at Severity Level IV, the NRC :s concemed

that, when it was determined that hot particles were present, an evaluation, to determine the

quantities and magnitude of the hot particle contamination, was not performed. Consequently,

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an appropriate interval for personnel frisking for hot partici t9 was not established. Without

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these controls, there was a potentiel for skin exposures even more significant than the

exposure that cccurred.

With respect to the apparent violation involving the failure to follow procedures for the once-

through cteam generator (OTSG) locked high radiation area that was discussed at the

conference, the NRC concluded that the wutker that left the OTSG manway area unattended

with the high radiation area door unlocked failed to adhere to the requirements of your locked

high radiation area AP. However, based on the information provide j at the conference and

during subsequer't telephone conversations with Mr. Etheridge of your staff, the NRC

concluded that the potential for inadvertent entry into the high radiation area was low. The

manway opening was continuously monitored at a remote location with a video camera and

the individual monitoring the opening by camera was in direct communication with personnel

in the close proximity of the unlocked manwsy. Therefore, because it was licensee identified;

was correct 6J immediately; and was not ropetitive within the last two years, the violation of

the locked hig5 radiation area AP will not be cited in accordance with Section Vll.B.1 of the

Enforcement Policy.

You are requirnd to respoad to this istter and should follow the instructions specified in the

enclosed Notice when preparing your response. The NRC will use your response, in part, to

determine whether further enforcement action is necSwary to ensure compliance with

regulatory requirements,

in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its

enclosure, and your response will be placed in the NRC Public Docurr.ent Room (PDR).

Sincerely,

H ert J. Miller

Regional Administrator

Docket No. 50 289

License No. DPR 50

Enclosure: Notice of Violation

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cc w/ encl:

J. Fornicola, Director, Nuclear Safety Review

M. Ross, Director, Operations and Maintenance

D. Smith, PDMS Manager

TMI Alert (TMIA)

M. Laggart. Manager, TMI Regulatory Affairs

E. Blake, Shaw, Pittman, Potts and Trowbridge (Legal Counsel for GPUN)

Commonwealth of Pennaylvania

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DISTRIBUTION:

PUBLIC -

SECY

CA

LCallan, EDO

AThadani, DEDE

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JLloberman, OE

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HMiller, RI

FDavis, OGC

SCollins, NRR

RZimmerman, NRR

Enforcament Coordinators

Rl, Ril, Rlll, RIV

BBeecher, GPA/PA

GCaputo, 01

DBangart, OSP

HBell, OlG

TMartin, AEOD

OE:Chron

OE:EA

DCS

NUDOCS

DScrenci, PAO RI-

NSheehan, PAO RI

Nuclear Safety Information Center (NSIC)

NRC Resident inspector - Three Mile Island

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