ML20054F093
| ML20054F093 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/07/1982 |
| From: | J. J. Barton GENERAL PUBLIC UTILITIES CORP. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20054F089 | List: |
| References | |
| 4400-82-L-0071, 4400-82-L-71, NUDOCS 8206150210 | |
| Download: ML20054F093 (6) | |
Text
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GPU Nuclear
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P.O. Box 480 Middletown, P3nnsylvania 17057 717-944-7621 Writer's Direct Dial Number:
thy 7, 1982 4400-82-L-0071 Office of Inspection and Enforcement Attn:
Mr. Ronald C. Haynes, Director Region 1 U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Sir:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Inspection Report 50-320/82-01 This is in response to Inspection Report 50-320/82-01 issued April 1, 1982. The report contained two Notices of Violation (Appendices A and B).
Appendix A presented three apparent items of noncompliance to which we will respond in this letter. Appendix B presented one additional noncompliance. As noted in your transmittal 'etter of April 1, 1982, we have corrected the item addressed in Appendix B.
However, your letter did not reflect that GPU's correction of the situation included measure 3 oc prevent recurrence. After the exit interview, those measures were related to and found acceptable by Mr.
R. J. Conte, Senior Resident Inspector, U. S. Nuclear Regulatory Commission. Therefore, as discussed by Mr. S. D. Chaplin of TMI-2 Licensing and Mr. Conte, we vill not address the Appendix B citation in this response letter.
In accordance with the provisions of the inspection report, the required response date has been extended from May 1, 1982 to May 6, 1982. The extension was based on a discussion between Mr. R. J. Conte, Senior Resident Inspector, USNRC, and Mr.
S. D. Chaplin, TMI-2 Licensing.
Item A - Apparent Noncompliance (Severity Level IV)
Contrary to 10CFR50 Appendix B, Criterion VI and the approved TMI-2 Recovery Quality Assurance Plan, Revision 10, July 14, 1980, Section 3.2.1, "as of February 15, 1982, measures were not established to assure that operating procedures were controlled and reviewed for adequacy prior to the work initiation of a modification, when that modification prevented the proper imp'ementation of an operating procedure.
Certain Long Term "B" Cooling (LTB) System piping was disassembled without revision and review for adequacy of the associated operating procedure (2106-2.9, Revision 2. September 15, 1981).
This piping was used in the fill and vent evolution specified in the operating procedure for startup of the LTB System".
8206150210 820608 PDR ADOCK 05000320
- lear is a part of the General Public Utilities System O
fl Ponald C.'Haynes 4400-82-L-0071 Response-GPU concurs with the. noncompliance. As a result of our review of the citation, we have identified a deficiency in the_ procedural control of plant modifications.as further described below. Technically it should be pointed' out that the physical capability ~to perform the fill and vent evolution was never lost; only the procedural guidance for-doing so was invalidated. The flowpath designated in OP2106-2.6 was-only-one of.many alternate flowpaths avail-able. However, the alternate flowpaths were not described in the procedure.
A. temporary change notice to the procedure.
was prepared on February 26, 1982 to describe an appropriate alternate.flowpath.
The plant modification control system.has a provision for ensuring that operating procedures as well as emergency /.
~
abnormal, surveillance, maintenance, HP and chemistry procedures-are' updated upon completion of the modification and closeout of the modifications package. The provision is in the form of a closeout checklist in Administrative Procedure 104', Rev.
1, " Work Authorization Procedure". However,: there are. 3 requirements for this function to be completed prior to the completion of the closeout documentation package. To avoid recurrence of this problem the modification ~ controls procedures will be revised to require that a determination be made as to whether a procedural change is required prior to performing the modification in order.to ensure that Tech Spec required functions are not impaired. This action will be completed by May 28, 1982.
Item B - Apparent Nencompliance (Severity Level IV)-
Contrary to Administrative Procedure 1021B, Revision 8, between November 23, 1981 and December 30,1981, a change / nodification form and associated safety evaluation was not completed for a Job Ticket (Work Request) No. C8576, dated November :23,1981, and approved for work (by the Maintenance Department) on December 30, 1981. Administrative Procedure 1021B, Revision 8,~ January 13, 1981, Plant Modifications, paragraph 4.1.a requires, in part, that when a work request represents a change / modification to a system, the change / modification form and associated safety evaluation is to be completed.
This Job Ticket caused the construction of a fourth wall and the addition of heaters to an enclosure adjacent to the Borated Water Storage ' Tank (BWST).
This action enclosed certain BWST piping along with temperature sensors for primary heactracing that heat traced piping inside and outside of the enclosure.
+
Ronsld C. H ynns 4400-82-L-0071
Response
The fourth wall was constructed and the heater installed in l
cupport of maintenance activities (repair) on BWST piping j
components. The maintenance required de-energizing the heat l
trace for a section of BWST piping and thus alternate protection was provided by the temporary enclosure (fourth wall) and temporary heaters.
Maintenance support ac ivities such as those described above, i.e.
support activities of " repairs" as defined in AP 1021B, are not considered a change / modification in the context of AP 1021B.
Rather, it was seen as a work support measure in the same context as installation of a contamination containment device. As such, no change / modification form or its associated safety evaluation was required. The support activities are developed and reviewed as part of the job ticket package. As part of their normal job functions, it is the responsibility of the personnel involved with development and review of the job package to identify and account for system interfacing where and when applicable.
In the case of job ticket C8576, even though the normal development and review process was used, an oversight of the impact on the heat tracing external to the enclosure was not identified.
To correct this situation, the following actions have been or will be taken:
- Informal (non-documented) Heat Tracing training by the maintenance foremen was given within the Electrical Department to raise their technical expertise on these particular heat traces and their operation as a system.
- A training course on Heat Tracing Design, Trouble-Shooting, and Proper Installation will be given to the Electrical Maintenance Department by the Training Department and will be documented.
This training will be completed by December 10, 1982.
- All Maintenance personnel attending their Industrial Experience Section of training had this incident reviewed so as to be aware of this type of concern in the future.
In addition, a Standing Order of Memorandum (SOM) will be issued in the Maintenance Department discussing the need to identify and account for all interfaces where a repair support activity could affect the normal function of plant systems. The SOM will be issued and reviewed by all appropriate Maintenance personnel by June 4, 1982.
~
Ronald C. Haynes 4400-82-L-0071 Item C - Apparent Noncompliance (Severity Level V)
Contrary to proposed Technical Specification 6.8.1.c which states in part:
" Written procedures shall be.
. established.
covering the test activities of... radioactive waste management equipment" on January 8, 1982, a High Efficiency Particulate Absolute (HEPA) Filter on a vacuum cleaner (in the dry vac mode) was used without having established procedures for testing the integrity of the in-place HEPA filter. The vacuum cleaner was used as radioactive waste management equipment, at the 281' elevation of the Unit 2 Auxiliary Building.
Response
Because TMI-2 did not have personnel qualified to ANSI standard levels to perform DOP testing. TMI-2 routinely utilized either qualified TMI-l personnel or contractors to perform DOP testing of the HEPA filters throughout the unit.
These personnel utilized either contractor or approved TMI-l procedures and, hence, there were no TMI-2 procedures developed.
Also it was believed that the vacuum cleaners were received from the vendor after they had tested the HEPA filter in place and therefore did not require testing after receipt and prior to initial 2 sage.
In actuality, the filters were tested prior to shipment but not in place and therefore do require testing after installation.
To correct this situation TMI-2 Procedure OP 2104-4. 22, " Operating Handling, and Servicing of HEPA Filtered Controlled Vacuum Cleaners",
has been issued and implemented.
The corrective steps taken to avoid further violations consist of complying with the requirements of Procedure OP 2104-4.22.
Decon Supervisors / Foreman have been made aware of this requirement. All vacuums being used by the Decon group in TMI-2 have been DOP tested with filters installed.
Full compliance with the above has been accomplished as of April 21, 1982.
l
' Rondld C. Hrynes 4400-82-L-0071 In the Inspection Report transmittal letter, the NRC expressed concern about the implementation of GPU's management control systems that permitted Items A and B to occur.
Further, NRC requested that GPU describe those actions or plans to improve the effectiveness of GPU management control systems in the area of modification control.
CPU has reviewed Items A and B and initiated actions as discussed in the specific response for each item. Based on our review, GPU can identify no management control problems which are fundamental to both Items A and B.
Since GPU has addressed each area individuall'y and no common problems can be identified, G?U believes the'above qu'estio'n has been adequately addressed.
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n Ac i irector, TMI-2 JJB/SDC/jep CC:
Dr. B. J. Snyder, Program Director - TM1 Program Office Mr. L. H. Barrett, Deputy Program Director - TMI Program Office s
P METROPOLITAN EDISON COMPANY JERSE'l CENTRAL POWER AND LIGHT COMPANY AND PENNSYLVANIA ELECTRIC COMPANY THREE MILE ISLAND NUCLEAR STATION, UNIT II Operating License No. DPR-73 Docket No. 50-320 This letter is submitted in support of the Nuclear Regulatory Commission request concerning the April 1, 1982 letter transmitting Inspection Report 50-320/82-01.
The response to the subject Inspection is attached. Further, all statements contained in these responses have been reviewed and all such statements made and matters set forth therein are true and correct to the best of my knowledge, information and belief.
By b
A 't hg' p Etor, TMI-2 Sworn and subscribed to me this rw day of
, 1982.
By MA % %twg Notarf Public --
4 DARL A JEAN 8ERRY. NOTARY PU8 tlc MIDDLETOWN B0k0. DAUPHlN COUNTY MY COMMIS$10N EXPIRES JUNE 17.1985 Vember Penesf vama Association of Notaries i