ML19210A677

Responds Further to Apparent Violation Noted in IE Insp Rept 50-289/75-01.Corrective Actions:Plant Design Change C/M 0080 Reviewed & Determined Adequate & Not Involving Unreviewed Safety Questions

ML19210A677
Person / Time
Site:	Three Mile Island
Issue date:	04/09/1975
From:	Arnold R METROPOLITAN EDISON CO.
To:	Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
GQL-0922, GQL-922, NUDOCS 7910310481
Download: ML19210A677 (4)

Text

. . . .

n a c .,

t e (- .

7 " '

dfM2 .

l .' YE Nm~m .

l /

f /- METROPOLITAN EDISON COMPANY ~=. u~o ww. . r. arrmes.v:n. <: - / #

1 POST OFFICE sox 542 READING.PENNSYLVANI A 196c3 ,

TELEPHONE 215 - 929-0401 Acril 9, 1975 Gol 0922 Fr. Eldon J. Brunner, Chlef Reacter Operations Branch Office of Inspectio.2 and Enforcement Region I U. S. Nuclear Regulato27 Cc==ission 631 Park Avenue King of Prussia, Pennsylvania 19406

Dear Mr. Brunner:

Docket No. 50-289 Operating License No. DPR-50 Inspection Report 75-Oh In response to concerns your office has regarding our Operational Quality 9 Assurance program, the purpose of this letter and the attached enclosure is to:

a. address the apparent violation which resulted from your Mr. Spes.sard's February 2h-27, 1975, inspection of our Three Mile Island Nuclear Station, Unit 1, and

b. in addressing a. above, provide sufficient supple = ental infor=ation to also address your office's remaining, verbally expressed concerns regarding our response to your office's Inspection Report T5-01.

We trust that with this sub=ittal we have adequately addressed all the re=aining concerns that you may have had regarding our Quality Assurance progra=. Should you, however, have any additional questions or concerns, please do not hesitate to call.

Sincerely, Slined-R. C. AR':3LO R. C. Arnold Vice President RCA:DNG:tas

Enclosure:

Response to Notice of Apparent 14(10 173 Violation 7'. le : 20.1.1 i 7.T.3.2.1 7910810 [/

Metropolitan Idison Cenpany (Met-Id)

Three Mile Islend Nuclear Station Unit 1 (TMI-1)

Docket No. 50-289 -

9 Operating License No. DPR-50 g

h D Of@[J [

Inspection Report 50-2S9 / 75-Oh l]g $

Resconse to Notice of Antarent Violation Accarent Violation

" Contrary to Criterion III, Appendix 3,10 CFR 50 and the FSAR Section lA, Operating Quality Assurance Plan,Section III, plant dssign change C/M 0080, Modification of Diesel Generator Air Start Systes, was ccepleted during 1974 vithout receiving prior Generatio: I:gineering Department review and approval as required by Generation Ingineering Depar =ent Precedu e GP 1003, Control of Design Changec.

This infraction was identified by the inspection and had the potential for causing or contributing to an ocettrence . tith Safety Significance."

1. Backzround Infor=ation The apparent violation in question also constitutes a residual concern re-maining fros Inspection Report 75-01 (I.R. 75-01) in that:

a. of the 9 change codifications whose design review had been g questioned in I.R. 75-01

1. 1 of the 9 has been resolved (note: the fact that this ite= is resolved is ack=cvledged in I.R. 75-Oh, page 13, paragraph 1),

therefore, this ite= is no lo:ser of concern,

2. 7 others of the 9 had sufficient reviev/ approval d'oeu=entation as per the requirements of the Start-up and Test Program, therefore, these items are also not of concern, but

3. the 1 r-,Mning of the 9, which is the sa e C/M in question in this report, did involve che:ges to a TSAR described systen; contrary to what had been reported in our response to I.R. 75-01, it had not been shev: that su"ficient reviev/ approval documentation existei; and as a result, this change codification is again a subject in question in Inspection Report 75-Oh.

2. Corrective Actions I:=ediate: As i==ediate corrective action, the Met-Id Generation En$i neering Depart =ent has cocpleted a reviev cf C/9. 00cc, and based on this review a deter =ination has 'ceen rade that C/F COBO is adequate and that it does not involve any unreviewed safety questiens.

Long Tern: Based on a canagetent re /" ev of this subject area it has been g deter =ined that the only Che .ge Medi_ications for,vhich additional long tern corrective actions need to ba = t a- are those vhich were initiated by rrenps cutside of tha " ' - 5 e r- ? ct e N pply '"555) vendor nni 1490 174

a,. .. ,

D**D ~D'%

eo e . S. n g Architect Engineer organizatiocsduring the ti=e period froc issuance of W the 'IMI-1 Operating License to Cen=ercial Operation (i.e. April 19, 1975, th cuSh September 1,197~) . Feason f r having cade this determination Ere E3 follovs:

a. for the time period trior to the date of obtaining our Operating License (April 19, 1975): the technical adequacy and safety icplications of initia2. designs, and design changes initiated prior to AI,ril 19, 1975, were pro _erly reviewed and approved in the process of preparing and -*-ding the Safety Analysis Report; therefore, there are no r_ ainin concerna regarding Change Modifications initiated vittin this time veriod,

b. for the ti=e period frc: the date cf ec : ercial eteration (Se terber 2,1975), to the tresent: the Met-Ed CQA plan, and i=plementing procedures have been in effect to control all design charges; ery design changes initiated during this period have been subjected to the controls of that plan and its implementing procedures (including those initiated by contractors and sub-contractors); therefore, it is the Licensee's tosition that there shculd be no recaining concerns rega-ding the Change Modifications initiatec vithin th s tire terici.

c. for the time period yet to be adiressed (i.e. frem the date of issuance of the Orerating License (Acril 19, 1975) to the date of g C-arcial Oeeration (Settember 2,1975):

.. the Design Control procedures which vere in effect under part

a. above vere continued for all design changes initiated by the NSSS vendor and Architect Engineer, and further revieved by Met-Ed =anage=ent through use of its contracted Start-up and Test Group; therefore, there are no recainine concerns regarding these tyces of chenre =ciificatiens initiated within this tine teriod, but

2. for those design changes initiated in this tire teriod by groues other than the FSSS vender and Architect Enrineer, there still exists sone der: ee of concern in that we are still in the process of further reviewing the status of an all inclusive tabular listing of these types of change =cdifications, to ensure that ncne of them hhve been co=pleted withcut proper design control and safety revievs.

Es.ving identified, therefore, what ve censider to be the types of Change Meiifications which require long te: corrective actions, additional efforts vill be taken in this rege.-d as follevs: ,e

a. by April 30, 1975, 1490 1/3

1. a review of the tabular lis-ing referenced in 2.c.(2) above vill be ec=pleted and vill serve to identify any design review and/or safety evaluation problers that cay exist for the change

@ codifications in question, and

2. te previde ourselves vit'. : rther usurance that there exists no

e problems in the Change Modifica:icas i sitiated after the date of Cc=mercial Operation., the subject above referenced review will be extended to encompass all Change Modifications initiated from the date of Commercial Operation (September 2,1974) to the present, and

% any design review or safety evaluation problems identified by the subject review vill be corrected by June 9, 1975 .

3 Comoliance Compliance vill be achieved by June 9, .1975 D. * * *D'T -

oo o M ,

S. . _a

k. Additional Item of Infor=ation In response to a verbally expressed Co 'ssion concern regarding the General Office Review Board (GORB) review of audi .s, please be advised that in addition to the post quarterly audit progras repon actions described in our response to I.R. 75-01, additional actions vill be taken as follows:

1. the Manager OQA vill send the Go?3 Audit Subconmittee Chairman a projected 6 month schedule of audits,

2. the GORB Audit Subcommittee vill determine which audits they vill vant to g review, and will so infors the Manager OQA, 3 following actual completion of the audits that the GORB Audit Subcommittee desires to review, the Manager OQA vill send the subcommittee chairman the audit findings when available, L. the GORB Audit Subec=mittee vill review the subject audits, document their review, and report to the G033 on both the projected 6 month schedules and results of their audit finding reviews. The GORB will then make whatever additional recommendations they ray deem appropriate to the President of Metropolitan Edison Company.

@ 1490 176