ML20028B416
| ML20028B416 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/27/1982 |
| From: | Kanga B GENERAL PUBLIC UTILITIES CORP. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20028B403 | List: |
| References | |
| 4410-82-L-0015, 4410-82-L-15, NUDOCS 8211300364 | |
| Download: ML20028B416 (5) | |
Text
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P.O. Box 480 Middletown, Pennsylvania 17057 717-944-7621 Writer's Direct Dial Number September 27, 1982 4410-82-L-0015 Office of Inspection and Enforement Attn: Mr. Ronald C. Haynes, Director Region I US Nuclear Regulatory Comnission 631 Park Avenue King of Prussia, PA 19406
Dear Sir:
Three Mile Island Nuclear Statiun, E.it 2 ('IMI-2)
Operating License No. DPR-73 Docket No. 50-320 Inspection Report 50-320/82-10 This is in response to Inspection Report 50-320/82-10 issued Aug at 26, 1982. The report dealt with the Management Conference held July 29, 1982, at the NRC Region I Office in King of Prussia, PA. The Inspection Report presented one apparent item of noncompliance.
APPARENE VIO1ATION (SEVERITY LEVEL IV)
"As a result of the inspection conducted on March 21 - April 24, 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 XVI, and the accepted Quality Assurance Plan Section 8.1 require in part, that conditions adverse to quality such as deficiencies or nonconformances are promptly identified and corrected, and that corrective actions be taken to preclude repetition."
" Contrary to the above, between June 18, 1980, and January 8,1982, an identified deficiency important to safety ventilation systems (Reactor Building Ventilation and Purge Systs, Auxiliary Building Heating and Ventilation Systen, Fuel Handling Building Heating and Ventilation System), was not properly corrected in accordance with plant drawings /
specifications'and the filter train bypassing mechanism existed because the under-drain system cleanout drain holes did not have carbon steel plugs as required by plant drawings. 'Ihis deficiency was not identified I
as a nonconfonnance until March 3,1982."
'*Ihe improper corrective actions taken were the use of tape or cardboard to plug the " cleanout holes. Filter train bypassing by particulate radioactivity was observed on January 8, 1982, on the Auxiliary Building and Fuel Handling Building Heating and Ventilation System."
8211300364 821124 lear is a part of the General Public Utihties System PDR ADOCK 05000320 0
o Mr.." Ronald C. Haynes 4410-82-L-0015
Response
GPU concurs with the above citation. As indicated at the July 29, 1982, Management Conference between GPU and NRC, there did exist a deficiency in that certain HVAC drains designed to be plugged were, in fact, covered with tape.
.One of the main contributors to the existence of the taped drains resulted from insufficient clarity of the designated task and resolution on the job ticket (work request). This deficiency manifested itself in the completed work request #C5047 issued Jtme 18,1980. % e work request was issued to, mong other things, replace.the drain plugs in one Reactor Building Ventilation System cabinet. However, the inpleented fix did not satisfactorily follow tne request in that tape was used to cover the drains. A mechanism which can help in preventing this type of problem has been developed. It will foster ':etter cannonication between the Plant Engineering and Maintenance Departments in addition to closing the loop with respect to work request documentation. This mechanism is discussed further later in this response.
The corrective actions taken specifically related to replacing the ventilation cabinet drain plugs is discussed in IER 82-011/01L-1 dated September 16, 1982 (4410-82-L-0011).
Additionally, GPU is investigating the adequacy and clarity of other coupleted job tickets. In this respect, GPU is performing a review of coupleted job tickets to ensure this was_ not a generic problem.
As part of the resolution of generic problems discussed by GPU and NRC at the Management Conference on July 29, 1982, GPU is executing a variety of tasks designed to inprove the TMI-2 Division performance. The following is a stmmation of those tasks, both specific to this event and those more general in nature.
TMI-2 Division Organization The IMI-2 Division is being reorganized to provide additional and nore effective integration of GPU and GPU contractor activities and to increase management attention to all aspects of the TMI-2 recovery. The reorganization is being l
accanplished in a two-phase process as previously described to the NRC in GPU letter 4400-82-L-0046 dated August 5, 1982.
The initial phase of the reorganization, instituted Septaber 1,1982, will effect (inplement) a great deal of the intended goal of maximizing available resources by consolidating and streamlining the two organizations. For the most part, the reorganization will not eliminate any present functions, but sinply change the functional location within the organization to inprove the effectiveness of the function and its interaction with other functional areas.
The second phase of the reorganization will nodify the safety review process presently described in the Technical Specifications. GPU intends to inplement a Safety Review Group to replace the Plant Operations Review Conmittee (PORC) and Generation Review Conmittee (GRC), but because of the need for a Technical Specification Change to inplement the new process and the timeliness required for the reorganization, this phase will not be executed until the last quarter of 1982.
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Mt Ronald C. Haynes 4410-82-L-0015 i
IMI-2 Division Procedures i
GPU has been developing a series of procedures which would provide an improved oversight capability for system procedures, maintenance, and modification control. The concepts detailed in these procedures, although not specifically developed due to this occurrence, will alleviate many of the adninistrative type deficiencies evidenced in this event. Following the reorganization of the IMI-2 Division of GPU Nuclear Corporation, the new set of adninistrative procedures will ccanence to be inplemented. A goal of inplementing 80% of the presently drafted procedures by the end of 1982 has been established. This goal would result in inplementation of approximately 45 procedures by the end of 1982.
I o The procedures utilize a philosophy of a " cognizant engineer". This concept requires all work on a given system to be reviewed by a cognizant engineer knowledgeable of that system. In addition, the presently used job ticket /
work request systen will be replaced by a more versatile doctanent called a thit Work Instruction (LMI). The LMI, when used in the capacity of the job ticket / work instruction (i.e. for maintenance items), will be required to i
have the cognizant engineer's approval prior to work. In addition, the coupleted LMI will be returned to the cognizant engineer for review after job coupletion. This will provide the opportunity for the cognizant engineer to maintain " cognizance" on specifically what work was done and how it was acccmplished for any system under his responsibility.
o hse procedures will also coordinate the various event reporting mechanisms in use at IMI-2 and will include a doctanented review for reportability of these events. These procedures, in particular, will provide a better method to discover similar situations so that action can be taken to correct potential problems.
o The TMI-2 specific procedure governing management of the IMI-2 Licensing Action Iterr. System will be issued with the above discussed procedures. This procedure is similar to the Technical Functions Action Item procedures, which had j
jurisdiction in TMI-2 until a recent organN ional realigrunent, except that t
it incorporates a broader scope of required application.
Radiological Controls / Operations Connunication i
The Directors of the Radiological Controls and Operations Departments have inproved their direct connunications since the beginning of 1982. In addition, they have endeavored to inprove cannonications at all appropriate levels between the two departments. This is most notably evidenced in the Radiological Work Management Workshop conducted in May of this year.
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The Workshop consisted of upper management from the Operations and Radiological Controls Departments providing supervisory and foremen level personnel a i
presentation of Rad Con work practices and concepts as they would apply to their daily functions. Approximately 60 individuals participated in the Workshop.
Additionally, the normal periodic Rad Con awareness meeting involving Rad Con, Operations, and other affected organizations (depending on subject material)
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continue to be held with an increased level of awareness of radiological issues.
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Mr:. Ronald C. Haynes 4410-82-L-0015 Review of Coupleted Work Request GPU is performing a review of closed job tickets (work requests) for
- 1) adequacy in addressing technical requirments in the preparation of work requests, and 2) for the adequacy of detail in the job ticket resolution-I section to ensure the maintenance activities performed were in canpliance with design criteria. Wis review is to verify that job tickets provide sufficient detail at issuance to assure plant design is maintained and to essess whether design was inpacted by the work performed.
W is review, being wrformed by the GPU Quality Assurance Department, includes a 107, sanpling of tm more than 3,500 job tickets issued since Mamhar,1978, that are classified as Inportant to Safety (ITS). % e method of selecting this sanpling was-by reviewing the maintenance job ticket log and identifying those ITS job tickets that were conpleted and of a nature which had a potential for design change.
In addition, the review encanpasses 100% of all job tickets (ITS and non ITS) related to IMI-2 ventilation systems, approximately 1,100 additional job tickets.
It is anticipated that the initial review and analysis for generic deficiencies will be conpleted by October 15, 1982. However, a firm schedule for the overall task cannot be defined until the initial steps are conpleted.
GPU will provide additional information regarding the schedule by November 1, 1982.
Doc ment Control
%e contract for appropriate outside vendors will be modified to include require-ments for a signed off checksheet which will ensure reports relating to activities concerning safety related equipment are provided to GPU at the completion of their work. W e report (s) will, by contractual stipulation, be forwarded to the docment control center. W is will ensure that all of these docments will be available in one location.
Bis has already been accanplished for the contrac / contractor that wrforms GPU's ventilation testing. Changes to the remaining contracts will'm effected when the contracts are renewed.
In sunmary, GPU has or is taking many steps to inprove the effectiveness of the organization. hose which remain to be conpleted are listed below with their corresponding conpletion date.
-- Conpletion af tie reorganization Decenber 31, 1982 Issuance of 80% of presently drafted December 31, 1982 i
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procedures
-- Finish review of coupleted work requests Novenber 1,1982 (provide final schedule) j
-- Modification of contracts to require December 31, 1982 i
docment distribution
. 1 p!r' Ronald C. Haynes 4410-82-L-0015 If you have any questions, please contact Mr. J. J. Byrne of my staff.
Sincerely, B. K. Kanga Director, M -2 BKK/SDC/jep CC:
L. H. Barrett, Deputy Progr e Director - M Progra Office Dr. B. J. Snyder, Progre Director
'IMI Progra Office Sworn and subscribed to before me thisa w day of e
, 1982.
% A m w ~ A a ~,,-
Notary Pubric 4
DAHLA JEAN MRRY. NOTARY PUBUC MIDDLETOWN BOR0. DAUPtM CONTY MV COMMISSION [?.?!8!! JUNE 17.1985 Member. Pennsy!vania Association of Notanes