ML20033B512
| ML20033B512 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/12/1981 |
| From: | Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20033B508 | List: |
| References | |
| 50-289-81-22, NUDOCS 8112010482 | |
| Download: ML20033B512 (3) | |
Text
i APPENDIX A NOTICE OF VIOLATION Metropolitan Edison Company Docket No.
50-289 Three Mile Island Unit 1 License No. DPR-50 As a result of an inspection conducted at Three Mile Island, Unit 1, on. August 17-21, 24-28, 31; and September 1 - 2, 1981 and in accordance with Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following' violations were identified:
A.
10 CFR 50, Appendix B, Criterion VI, Document Control, requires that the issuance of documents, drawing and procedures be controlled so as to assure adequate review, authorized approval and release, and distribution and use at the work location.
Three Mile Island Operational Quality Assurance Plan (0QAP), Revision 9, also requires that these measures be established to control such activities. The CQAP paragraphs 3.2.2.5.and 3.2.2.6' state the following:
"5. Document distribution must be sufficient to assure that the documents are readily available at convenient locations to responsible personnel prior to commencement of work.
- 6. Document transmittal and maintenance measures shall be incorporated in document control systems to prevent inadvertent use of voided, superseded or obsolete documents."
Contrary to the above:
On August 25, 1981, one of six contractor erection drawings and three of seventeen contractor assembly drawings in use at the work location for the erection of an environmental barrier between Unit 1 and Unit 2 were not of the latest approved revision.
On August 19 through 28, 1981, numerous controlled drawings located in the Control Room and other controlled drawing locations did not reflect the latest system information as a result of system modifications.
On August 19, 1981, a Control Room operator' verified the accuracy of a proposed system tagout using Drawing C-302-203, which was i
annotated as having Design Change Notices (DCN's) 0057, 0100, and 0112 applicable to it.
These DCN's were not available nor were they i
used by the operator.
0FFICIAL RECORD COPY I
8112010482 811112 PDR ADOCK 05000209 PDR G
. ~,
5 Appendix A 2
Or. August 24 and 25, 1981, uncontrolled drawings marked "For Informaticn Only" for the Integrated Control Systems (ICS) and
~Nonnuclear Instruments'(NNI) were being used by Instrument and Control (I&C) technicians at work locations in the Control Building.
On August 19 through September 2, 1981, four system drawings annotated as control copies, and three sketches from a procedure were posted, and a drawings notebook was maintained at the Radwaste Panel work location in the Auxiliary Building. None were in the controlled system and two of the posted drawings were not of the current revision.
On August 19 through 28, 1981, a laminated chart was posted on the side of Control Room Panel PLF that contained a summary of set points and action plans; an engraved placard was permanently mounted to Control Room Panel PLF that summarized the thermal discharge limits required by Technical Specification Appendix B; and, four engraved placards were permanently mounted on the Makeup Pumps breaker panels located in the Control Building that summarized Makeup Pump breaker precautions required by Technical Specification Appendix A, part 3.1.12.3.
None of these placards / charts were controlled by administrative procedures to assure that they would be updated should changes be made to the procedures or Technical Specifications on which they were based.
On August 19 through 28, 1981, thirteen errors were detected in the posting and distribution of drawings and aperture cards which included out-of-date drawings at a controlled drawing location; failure to post controlled drawings with the latest applicable design change. notice; and, annotating drawings with the incorrcct design change notice.
On July 7 through September 2, 1981, the replacement of existing engineering procedures by new technical functions procedures (a manual) and the use of new versus old procedures was not adequately controlled in that user personnel were not fully aware of the manner in which this transition would occur.
This is a Severity Level IV Violation (Supplement I).
Technical Specifications 6.8.1 and 6.8.2 requires that written procedures B.
and administrative policies shall be established, implemented and maintained... and that each procedure and administrative policy and changes thereto, be reviewed by the Plant Operations Review Committee and approved by the Unit Superintendent prior to implementation.
OFFICIAL RECORD CODY i
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t Appendix A
'3 Contrary to the above, on August 20, 1981, Procedure AP1001C, " Drawing Distribution and Control", which was being implemented as the procedure for control of drawing and aperture cards, had not been reviewed by the Plant Operations Review Committee and had not been approved by the Unit Superintendent.
This is a Severity Level VI violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Metropolitan Edison Company is hereby required to submit to this office, within thirty days of the date of this notice, a written statement or explanation in reply, including:
(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation. Where good cause is shown, consideration will be given to extending your "esponse time.
The responses directed by this Notice are not subject to the. clear &nce procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
NOV 12 196f 1 sinc 131; cod By:
h R. R. Keimig, Chief, Projects Branch #2,.
Div' don of Resident and Project Inspection OFFICIAL RECORD COPY