ML20028F438
| ML20028F438 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/17/1983 |
| From: | Kanga B GENERAL PUBLIC UTILITIES CORP. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20028F431 | List: |
| References | |
| 4410-83-L-0010, 4410-83-L-10, NUDOCS 8302010353 | |
| Download: ML20028F438 (5) | |
Text
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GPU Nuclear Corporation 3 Nuclear
= n g s s 48o 8
Middletown, Pennsylvania 17057 717 944-7621 TELEX 84-2386 Writer"s Direct Dial Number:
January 17, 1983 4410-83-L-0010 Office of Inspection and Enforement Attn: Mr. Ronald C. Haynes, Director Region I US Muclear Regulatory Cmmission 631 Park Avenue King of Prussia, PA 19406
Dear Sir:
Three Mile Island Nuclear Station, Unit 2 (IMI-2)
Operating License No. DPR-73 Docket No. 50-320 Inspection Report 50-320/82-12 This is in response to the subject Inspection Report issued November 30, 1982, in which one apparent item of noncompliance was presented. GPUNC concurs with the violation as evidenced in the Inspection Report with carments and additional information provid:d on the specific examples as indicated below.
This citation is repeated below, the nunbering was added for clarity, followed by GPUNC's response to the violation.
APPARENT VIOIATION (Severity Imvel IV)
As a result of the inspection conducted September 12 - October 9, 1982, and in accordance with the Federal Register Notice-(47 FR 9987) dated March 9,1982, the following violation was identified.
10 CFR 50, Appendix B, Criterion VI requires in part that docunents affecting quality (instructions en:1 procedurec) including changes thereto are reviewed for adequacy. The NRC approved Recovery Quality Assurance Plan, Section 3.2.2, requires, in part, that review, approval, and issuance criteria for documents and their revisions assure adequate technical and quality requirenunts are met prior to issue.
Contrary to the above, the following procedures / instructions or procedure changes affecting quality were not technically adequate in that:
- 1) From September 10,198e, to October 9,1982, Operating Procedure 8302010353 830124 ition is a subsidiary of the General Public Utilities Corporation PDR ADOCK 05000320 g
- N Mr. Ronald C. Haynes 4410-83-L-0010 (OP) 2104-10.2 caused various Limiting Conditions for Operation, es described in the Technical Specification.(TS) to be exceeded wr the encay hear reaval systes and nuclear service closed cooling system.
- 2) On Septsber 2,1982, Temporary Change Notice (ICN) 2-82-362 dated September 2, 1982, to OP 2104-10.7 did not provide sufficient technical guidance for taking a Reactor Coolant System sample.
- 3) As of Septaber 3,1982, Work Package (WP) D-0041, dated September 2,1982, did not provide ufficient guidance to ensure that protective covering on the reactor vessel seu..a structure would be properly installed to prevent hydrogen gas accumulation under the covering.
- 4) As of October 6,1982, the Quick look (QL) series of procedures did not provide for samples nor establish. frequency of samples to ensure that combustible gas concentrations did not accmulate in the Reactor Coolant System (RCS) spaces.
RESPONSE
- 1) GPUNC concurs with this finding. The exceeding of the Tech Specs involved the nonperformance of surveillance for three Technical Specification required syst as. The surveillance procedures involved are:
4303-M-25 Decay Heat Closed Cooling Water P mp Operability and Valve Operability Test 4303-M30A/B Nuclear Services Closed Cooling Water Pmp Operability Test and Valve Operability Test 4303-Q3 Mini Decay Heat Removal Pmp Functional Test These surveillances were initially delayed to allow continuance of the Quick look project. The delay was necessary and intentional to ensure control over potential boron dilution accidents as discussed in Appendix C of the Quick Inok Safety Evaluation submitted on July 6, 1982, via GPUNC letter 4400-82-L-0110, and approved by the KRC (Dr. B. J. Snyder to J. J. Barton dated July 13, 1982).
Following NRC approval of the Quick look Safety Evaluation and impleenting procedures, GPU depressurized the RCS on July 14, 1982.
Had the RCS been repressurized after the originally projected two week schedule, surveillance performance would not have been adversely impacted (i.e. the surveillance testing would not have been delayed beyond the allowed surveillance schedule flexibility provided in Recovery Operations Plan Section 4.0.2).
The cause has been identified as the failure, on the part of GPUNC, to anticipate the need for, and to have GPUNC submit in an expeditious fashion, a request for a change to the Unit 2 Recovery Operations Plan once the schedule for the Quick look was extended such that it could
Mr. Ronald C. Haynes 4410-83-L-0010
~ N-extend the need for suspending the performance of required surveill::nce testing.
Recovery Operations Plan Change Request No. 21 was submitted on Noven,cer 11, 1982, via GPUNC letter 4410-82-L-0043. It would have allowed suspension of surveillance testing via NRC approved procedures pursuant to Technical Specification 6.8.2 without requiring further changes to the Recoverf Operations Plan. However, the requested change was not approved by the staff Neause this change would allow tenporary modifications to Jne Recovery Operations Plan which would not be on th docket.
Therefore, an alternate request was submitted on December 9, 1982, which requested a temporary exemption for the above affected surveillances. However, the Reactor Ccolant System was refilled prior to the NRC receiving and acting on this request and, therefore, the basis for the request no longer existed and it was denied.
This event has been utilized as an exanple to various departments in GPUNC to indicate the need to ensure change requests to upper-tier Licensing docuaents are initiated as necessary.
- 2) GPUNC amended the subject TCI to specify thJ depth to thich the tubing was to be lowered.
- 3) GPUNC concurs with this finding. The covering over the service structure was initially utilized to ensure that water for decontamination would not wet' the APSR drive motors.
However, short'y before the installation, a potential concern was identified. At the time this covering was installed, the RCS was being vented via opened control rod drive motor tubes. Since gas generation was occurring, it was deemed appropriate to configure the covering so that no questions would exist about entrapment of generated gases. Wile internal technical discussions continued about the abili,ty of the herculite covering to cor.tain gas, it was decided not to nold up installation until pursuit of this topic was coupleted. Subsequently, it has been shown that hydrogen gas l
would not be contained by the herculite material.
To ensure that a non-entrapping configuration was utilized, the work package was briefly amended. However, the instructions
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were apparently not explicit enough to preclude misinterpretation of the intended configuration.
As a result, the herculite cover was erected in a configuration different fr m that intended by the instruction. It was determined that the cover, as erected, was still acceptable for its intended functions.
This specific event was discussed on Septenfoer 21, 1982, with appropriate Site Engineering personnel as a training aid for GPUNC work package review responsibilities.
Mr. Ponald C. Haynes 4410-83-L-0010 It was streesed thz a considered inprovment in the quality of written instructions would be to define the function of the instruction (e.g. a note to say not to install covering in a unnner which pennits gas trapping pockets) or to provide an installation sketch. No further action is considered necessary.
- 4) Based on subsequent discussions with NRC personnal, GPlNC understands the the basis for this citation is thac the Quick look series of procedures did not adequately address precautions and maritoring of combustible gas concentrations which could acctmulate in the Reactor Coolant System CG) spaces. GPlNC concurs that more attention to the acetadation of combustible gases should have been provided in a timely ma cer after the initial exransion of the Qt:ick Im period.
Beginning Septaber 3,1982, a program to periodically monitor the gas generation in the Reactor Pressure Vesecl (RPV) high points was inplemented. Gas samples were taken during this progran to determire if gas concentrations were combustible or trending toward combustibility. The results of this program showed that the offgassing from the primary systs was steadily decreasing. 'Ihis sampling also confirmed that a carbustible gas ccuposition never existed in the steam generator or pressurizer high points.
This information was documented in the following letters:
Ictter from B. K. Kanga to L. H. Barrett dated Octo% r 8, 1982 "RCS Hydrogen Evolution" Iatter from B. K. Kanga to L. H. Barrett dated Novembe 8,1982 "RCS Hydrogen Evolution" The instructions for accomplishing the e.anplig and t'w c'ates for sampling are as follows:
_P ocedure/ Work Pa-k_ age, Date RCS location 2104-10.7/R-0032 September 3,1982 Entry 91 CRIM (Control Rod Drive Mechanism) 2104-10.7/R-0032 Septaber 16,1982 Enny 92 CRIM 2104-10.7/R-0032 September 15,1982 Entiy 93 CRIH 2104-10.7/R-0032 September 22, IM2 Entry %
CRIM 2104-10.7/R-0031 Septenber 24, 1982 Entry 97 CRIH 2104-10.2&l0.7/R-0032&
Septenber 29, 1982 Entrv 99 GIM, hot legs, and pressurizer R-0030 2104-10.7/R-0032 October 6, 1982 Entry 102 O'21 2104-10.7/R-0032 October 20, 1982 Entry 10?
CRIM 2104-10.7/R>D032 November 3, 1982 Entry 117 CRIM 2104-10.7/R-0032 November 17, 1982 Entry 123 GIH
' [ - Mr. Kanald C. Haynes 4410-83-L-0010 As can be seen by the tabulation, a procedure was in place to inple ent sanpling and it was utilized throughout the sanpling program. Since this sapling would best be enaracterized as an engineering test program, the smoling
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frequency was based on engineerin6 jwig-t La the sapling pngram developed. The sanpling frequency was detennined, not by the procedure used for the perfonnance of the sanpling, but ixcead, via the work package. 7his provided a measure of flexibliity in inplomnting the sanping frer ency comensurate with the overall program.
This response follows both GPINC letter 4410-82-L-0081 dated Deceber 30, 1982, and the GPlNC/NRC meeting of Jruary 6,1983, both of which indicated that several items were required to be resolved / discussed prior to submittal of thin response.
If you have any questions, please call Mr. J. E. Larson of my staff.
Sincerely, m
B. K. Kanga Director, IMI-BKK/JJB/SDC/jep CC: Mr. L. H. Barrett, Deputy Program Director - TMI Progran Office Dr. B. J. Snyder, Program Director - IMI Program Office n-r~,-,,
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