IR 05000289/1987001

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-289/87-01

ML20236B011
Person / Time
Site:	Three Mile Island
Issue date:	03/03/1989
From:	Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Hukill H GENERAL PUBLIC UTILITIES CORP.
References
NUDOCS 8903200280
Download: ML20236B011 (2)

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, , . MAR 0 3.1989 i

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s Docket No.150-289

' GPU. Nuclear Corporation. "<

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ATTN: Mri H. D.~ Hukill- -

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Vice President and Director.of'TMI-1-

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JMiddletown,' Pennsylvania 17057 e

Gentlemen:.

F:  : Subject: . Inspection No. 50-289/87-01, This refers:to your' letter dated January 27,:1989,- in; response to our' letter'

- dated December.29,:1988. E Th'an'k? you' for1 informing. us Jof- the corrective -and. pre v~ entive actions documented-

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in your. letter. These actions will:be examined during a future' inspection.'of.

your, licensed program.

,, '~Your'cooperationswith usLis-appreciated.

Sincerely,

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i cririmi Elsra2 By:

Ja: quo P. DutT

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Jacque~P. Durr, Chief.

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Engineering Branch Division of Reactor Safety i. cc:

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T. G.;Broughton, Operations and Maintenance Director, TMI-1~

C. W. Smyth, Manager, TMI-1 Licensing-

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R. J. McGoey, Manager,;PWR Licensing .

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H E. L. Blake, Jr. , Esquire TMI-Alert (TMIA),

R. Susquehanna-Valley Alliance (SVA)

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J Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Pennsylvania

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0FFICIAL RECORD COPY RL TMIl 86-06 - 0001.0.0 02/09/89 (, ;

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' Region I Docket Room (with concurrences) 1 Manage:cnt ^::f:t:nt, ORMS (,;/c cac'). 1 DRP Section Chief-

- R. Hernan, PM, NRR i K. Abraham, PA0 i Rob'ert _J. Bores, DRSS i

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er's Direct Dial Number:

C311 -89-2010 Mr. William Region I, Regional Administrator US Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

Dear Mr. ' Russell:

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

Operating Licensing No. DPR-50 Docket No. 50-289 j Response to Notice of Violation in Inspection Reports No. 86-06 and 87-01 In accordance with 10CFR 2.201, enclosed is GPUN's response to the Notice of.

Violation in Appendix A to Inspection Reports No. 86-06 and 87-01. GPUN accepts the violation and points out that it reflects Equipment Qualification-documentation existing in mid 1986/early 1987 and does not reflect the present conditions of the EQ files which GPUN believes are in good condition. It should also be pointed out that the equipment associated with this NOV has '

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been and remains qualified to perform its intended safety function. This response confirms the multiple discussions we have had with your staff which addressed both specific and general program issues associated with Equipment Qualification.

Sincerely,

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H. D. u ill Vice President & Director, TMI-1 ( HDH/RJM/imi cc: Resident Inspector R. Hernan, NRC Document Control Desk Sworn and subscrib d to ore me this day of Attachment be"d dainiu4

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,1989.

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NOTARIAL SEAL

{ SHARoN P.BRCrNN, NOTARY PUBLic j

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MIDDLETcWN BORO, DAUPHIN coVNTY //fl% .

MY COMMISSION EXPIRES JUNE 12,1989

/ Notary /ublic Umy,Nxthm Assoutionof Notaries j 8052f GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation  !

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Enclosure to GPUN' Letter l

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NOTICE OF VIOLATION 10CFR 50.49(f) and (j), respectively, require tha't (1) each item of electric equipment important to safety shall be qualified.by testing ac.d/or analysis of identical or similar equipment, and the qualification based on similarity ,

shall include a supporting analysis to show that the equipment to be qualified I is acceptable; and, (2) a record of the qualification shall be maintained in 1 an auditable form to permit verification that each item of electrical i equipment important to safety is qualified and that the equipment meets the i specified performance requirements under. postulated environmental conditions. l Contrary to the above, at various times after November 30, 1985, certain environmental qualification files did not include the required documentation (

to demonstrate environmental qualification as evidenced by the following j examples:

1 1. As of August 1,1986, the NRC determined that there was inadequate test or l analytical information.available at the time of. the inspection to l establish ' qualification of installed BIW cable. Qualification test data for Continental Wire and Cable Company silicone rubber was used to ,

establish the BIW cable qualification. However, the tested and the .

installed cable configurations are differ at. Analyses were not performed j to evaluate the differences between the cables.  ;

c 2. As of January 21, 1987, the.NRC identified EQ files that were not  ;

maintained in an auditable form to permit verification that each item of l electrical equipment was qualified for its application. Fifteen out of thirty-one files examined .were found to be deficient in installation .j instructions, accuracy, and performance requirements. )

3. As of January 21, 1987, the NRC identified the presence of a black  ;

phenolic material in the cam shafts for Limitorque MOVs RC-V-3 and j WD-G-3. These cam shafts were different from those previously established to be qualified. Prior to the inspection, there was no qualification data to support the use of the black phenolic cam shaft for use in a containment LOCA environment.

4. As of January 21, 1987, the NRC determined that at the time of the q inspection there was inadequate information to establish qualification of  !

Rockbestos cable. The effect of lowered insulation resistance on instrument circuits was not evaluated for a LOCA environment.

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5. As of January 21, 1987, the NRC' determined that at the time of the l

inspection there was inadequate information to establish qualification of '

Weed RTDs. The tested model was different from the installed model.

Further, there was no evaluation or analysis to show similarity between the .two models, Model 611 and 612. <

6. As of January 21, 1987, the NRC determined that at the time of the inspection there was inadequate information to establish-qualification of Foxboro Pressure Transmitters. Some of the test results for the effects of steam and radiation showed unusually high measurement errors. .These test anomalies were not addressed and no plant performance requirements were specified.

7. As of January 21, 1987, the NRC determined that of the time of the inspection there was inadequate information available to establish qualification of Static-0-Ring Pressure Switches. There were no test results to support qualification of the installed 9TA switches.

Static-0-Ring tests on switches with the TA housing either exhibited performance well below normal expectation or were not tested in a configuration similar to that installed at TMI-1. There were inadequate acceptance criteria and there was no similarity analysis between test specimens and the installed component.

8. As of January 21, 1987, the NRC determined that at the time of the j inspection there was inadequate information available to establish  !

qualification of Kerite splices (Model No. 55-NS-NVC-DISC). There was inadequate information to address differences between the installed and tested configuration. Test anomalies including water intrusion into the splice and other failures were not satisfactorily addressed. There were '

no acceptance criteria related to the required performance at TMI-1.

9. As of January 21, 1987, the NRC determined that at the time of the inspection there was inadequate information to support the qualification i of Kerite FR cable for use in harsh environments at TMI-1. The system l Component Evaluation Worksheet 9SCEW) for the Kerite cable used at IMI-1 I to support the use of Kerite FR insulated cable at TM101.  ;

All of the above items of electrical equipment are important to safety.

The above items are a Severity Level IV violation. (Supplement I). l

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. RESPONSE TO NOTICE OF VIOLATION ENCLOSURE TO GPUN LETTER

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, l RESPONSE TO NOTICE OF VIOLATION GPUN accepts the violation as stated.

This Notice of Violation (NOV) is based upon the condition of the Equipment Qualification (EQ) files as they existed in mid 1986 and early 1987. GPUN has taken action throughout 1986,1987 and 1988 to improve the files and upgrade the entire EQ program. Therefore, previous discussions apply in understanding GPUN actions related to this NOV.

On December 4,1986, a conference with the NRC provided an extensive discussion on EQ Management issues. This conference was documented in the NRC letter to Mr. H. Hukill, dated December 18, 1986. A followup letter from GPUN, number 5211-87-2098, dated May 15, 1987, further amplifies actions taken to address management issues. The May 1987 letter describes actions taken in 1986 and 1987 which remain accurate and applicable to concerns raised by this NOV.

A management meeting on March 10, 1987, provided an indepth discussion on the status / resolution of open NRC Inspection Items and the overoll status of EQ at TMI-1. The meeting covered the adequacy of the documentation in EQ files.

As a minor point of clarification, your NOV cover letter lists ten items of concern, yet Appendix A lists nine. NRC item 87-01-02 associated with the EQ files for Eaton cables is not listed in Appendix A. This response includes item 87-01-02 and therefore, we do not feel any correction of this minor inconsistency is needed.

Corrective Steps /Results Achieved GPUN took prompt action during the April 1986 and January 1987 inspections to correct the documentation deficiencies identified by the NRC. Nine file specific deficiencies were corrected during or imediately after the inspection. The tenth item dealing with file auditability has been completed. Specific corrective actions were discussed with your staff during phone conversations, the March 10, 1987 management meeting, and more recently, during the November 15, 1988 discussion with your staff. GPUN has worked hard to understand the root cause of EQ Program problems and has taken an aggressive approach to correct these problems. Therefore, looking beyond the items listed in your NOV letter GPUN has also taken the following actions:

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(1) A new and improved ' organization, ' dedicated' staff and leadership for the EQ program,

. (2) Augmented management' attention to the EQ program, (3) The format and technical depth of the EQ files has been upgraded to include industry understanding of EQ documentation requirements and to improve clarity, consistency and structure. . These efforts enhanced their.

auditability which correct the concerns-identified in this NOV.

Guidelines to achieve.this-upgrade have been used to provide additional assurance of. proper implementation. Every file requiring upgrade has undergone this . improvement.

These corrective actions have been implemented and/or are part of our continuing effort to-improve GPUN activities. ' As a result of these actions,.

we have achieved what we believe are fully auditable EQ files.

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Corrective Steps 'to' Avoid 'Further Violations Within GPUN there is increased Management' attention on~ establishing and maintaining well . documented EQ files. This Lattention has' led to program::

improvements that will ensure future control. There is also increased attention to major programs such as EQ to ensure that proper resources are applied with strong and effective management.

Date 'of Full Compliance.

Corrective actions ~ necessary for full compliance were completed or. implemented December 31, 1988.

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1 ..:.-. : RESPONSE T0 ENGINEERING REVIEWS

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In your letter of December 29,-1988, you also requested GPUN to."... discuss

.the broader area of your actions to improve engineering reviews and ' analysis in the _ equipment qualification' area and .other= areas requiring engineering reviews." As also recognized in your letter, this speaks to the Tech Support Self. Assessment (TSSA). 4 GPUN

has.made two presentations to the NRC on May.'23,1988 and September 21,.

1988 on the TSSA which were documented in Inspection Reports 88-05 and 88-24 respectively. Since the presentations and Inspection Reports summarize the program, we will defer to the Reports for a description of the program.

However, the Self Assessment encompassed the < issue of engineering reviews in all phases of .GPUN technical activities. This self assessment and resulting corrective actions are underway and will continue well'into'the future.' 'In your' summary of Inspection Report 88-24 you stated, "The technical support self-assessment meeting was informative'and the NRC staff expressed their satisfaction with the licensee's findings and actions planned to correct the weak areas of technical support."~ GPUN expects that this program will have a positive impact on all areas of technical support.

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