IR 05000289/1993014

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-289/93-14

ML20058P957
Person / Time
Site:	Three Mile Island
Issue date:	10/13/1993
From:	Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Broughton T GENERAL PUBLIC UTILITIES CORP.
References
NUDOCS 9310260021
Download: ML20058P957 (2)

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iA : 4 i ,0ctober 13, 1993

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. Dockst No.J50-289'

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_.Mr. T. Gary Broughton ,

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Vice President and Director, TMI-1

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GPU Nuclear Corporation .

ThreeLMile Island Nuclear Station.

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- P. O. Box 480

, .Middletown, Pennsyhr .a 17057-0191-f

Dear Mr. Broughton:

SUBJECT: NRC INSPECTION REPORT NO. 50-289/93-14 This letter refers ~ to your' September 27,1993 correspondence, in response to our August 18,

1993 letter.

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.L Thank you for informing us of the corrective and preventive actions documented in your

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letter.gThese actions will be examined during a future inspection of your licensed program.

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' Your 'c6 operation:with us is appreciate' d.  :

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Sincerely, p.

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A. Randolph Blough, Chief Projects Branch No. 4 Division of Reactor Projects

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. R. E. Rogan, TMI Licensing Director

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L M.' J. Ross, Operations and Maintenance Director, TMI-1 J. Fornicola, Licensing and Regulatory Affairs Director

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TMI-1 Licensing . Department

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E. Li Blake, Jr., Esquire;

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TMI-Alert (TMIA) '

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K. Abraham,' PAO , _ .

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Public Document Room (PDR) <

JJ Local Public Document Room (LPDR) I Nuclear; Safety Information Center (NSIC)

1NRC Resident Inspector, '

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Commonwealth of Pennsylvania l

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- Region I Docket Room (with concurrences)

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Middletown, Pennsylvania 17057 0480 (717)944 7621 Writer's Direct Dial Number:

(717) 948-8005 September 27, 1993 C311-93-2128

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. U. S. Nuclear Regulatory Commission Attn: Document Control Desk i Washington, DC 20555

Dear Sir:

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

Operating License No. DPR-50, Docket No. 50-289

" Reply to a Notice of Violation" - Inspection Report 93-14 Enclosed is the GPU Nuclear reply to the Notice of Violation transmitted as an enclosure to Inspection Report 93-14. i

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Sincerely,

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T.G.Brodhton .i Vice President and Director, THI-1 ]

Attachment cc: Region--I1 Administrator TM1-1 Senior Project Manager

.TMI Senior Resident Inspector

.g W GPU Nuclear Corporation is a subsidiary of General Public Utilities Corporation b

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• C311-93-2128-Page 1 NOTICE OF VIOLATION Technical Specification 6.8.1.a requires that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Revision 2, February 1978, Step 9.a, states that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures.

Contrary to the above, the licensee failed to adequately establish Surveillance Procedure 1301-8.2, " Diesel Generator Annual Inspection," in that the procedure did not specify the torque value for the emergency diesel generator (EDG) lubricating oil filter cover bolts. This deficiency resulted ,

in the oil filter cover bolts being improperly torqued from June 24, 1993 to July 1, 1993.

This is a Severity Level IV violation (Supplement I).

GPU NUCLEAR RESPONSE TO THE NOTICE OF VIOLATION This Notice of Violation (NOV) is related to an event which resulted when a maintenance technician improperly installed the lube oil filter housing cover

.on the IB Emergency Diesel Generator (EG-Y-1B). The details of this event '

were reported in Licensee Event Report (LER)93-006 which was submitted to the NRC_on August 2, 1993.

I. Reason for the Violation

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During -the annual inspection of EG-Y-1B, Procedure 1301-8.2 was the L governing procedure. As is typical for such inspection / maintenance activities, a vendor representative was available to provide supplemental information to augment the performance of this task. The intended scope of vendor representative guidance is primarily of a qualitative nature (i.e., the best way to take a measurement, troubleshooting suggestions, etc.). Procedural guidance regarding vendor representative assistance does not allow deviation from procedural instruction or deviation from 3 quantitative requirements (torque values, clearances, etc.) specified in j the procedure. If a quantitative requirement such as a torque value is missing from a component specific procedure, personnel should obtain this ,

value from one of the following sources in descending order: vendor manual, generic procedure 1410-Y-72, and Plant Engineering. Because the procedure did-not specify a-torque value for the lube oil filter cover L bolts in this instance, the maintenance technician asked the vendor for l guidance and received incorrect information.

p L Previous annual inspections of both EG-Y-1A and EG-Y-1B have not resulted in events of a similar nature, so it can be assumed that torque values used in 'che past were sufficient to prevent leakage.

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C311-93-2128 Page 2 f The reason for the violation can be attributed to four causes. These causes are as follows:

'1. Surveillance Procedure 1301-8.2 did not specify the torque value for the. lube oil filter housing cover bolts.

2. .The procedure biennial review checklist does not indicate torque values 'should be -included in job-specific procedures.

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3. The process to be used to obtain data concerning unspecified. torque values was not followed.

4. Management's expectation of what information vendor representation can. supply and be acted on without challenge was not clear to the GPU Nuclear technician.

II. Corrective Steps That Have Been Taken and the Results Achieved >

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.Following the lube oil filter leak, Plant Engineering determined the appropriate torque value for the lube oil filter housing, based on the recommendation of the filter housing vendor manual. The bolts on the lube oil filters of both EG-Y-1A and EG-Y-1B were retorqued to 120 foot pounds. Subsequently, procedures 1301-8.2, Emergency Diesel Generator Annual Inspection and 1405-3.2, Diesel Engine Maintenance, were reviewed for other pertinent missing torque values and were revised to specify the

' Plant Engineering ' approved torque value (i.e.,120 5 foot pounds) to *

assure the correct torque is.used during future maintenance actions

. involving the diesel lube oil filters.

III. Corrective Steps That Will be Taken to Avoid Further Violations 1. Component specific maintenance and surveillance procedures will be reviewed to. ensure appropriate specification of quantitative requirements (torque values, clearances, etc.) is included.

2. The procedure biennial review checklist will be revised to specify including quantitative requirements (torque values, clearances, etc.) in component specific procedures. l 3. Plant Maintenance will revise Administrative Procedure 1070 (TMI-1 Maintenance Plan) to ensure:

a. Personnel understand the process for obtaining correct quantitative values, such as torque values, if not included in the procedure.

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b. Personnel understand the scope of information a vendor representative should provide and that this information is primarily of a qualitative nature.

As an. interim action, Plant Maintenance will describe this revision to-AP 1070 in upcoming shop meetings.

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. Attachment 1C311-93-2128.

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'lV. Date of Full Compliance l All maintenance personnel will.have received the instructions to be given in. shop discussions, and the procedure biennial review checklist will-be

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revised by November 30, 1993. The TMI-1 Maintenance Plan (i.e.,, AP

'1070) will be revised by January 31, 1994. The component specific procedure review will be completed by December 31, 1995.

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