ML20199H595
| 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: |
| 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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NUCLEAR REGULATORY COMMISSION
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475 ALLENDALE ROAD
KING oF PRUSSIA, PENNSYLVANIA 1M06-14'$
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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:
(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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GPU Nuclear Corporation
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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
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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GPU Nuclear Corp sation
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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
NUDOCS
DScrenci, PAO RI-
NSheehan, PAO RI
Nuclear Safety Information Center (NSIC)
NRC Resident inspector - Three Mile Island
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