ML20040F543
| ML20040F543 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/13/1982 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20040F538 | List: |
| References | |
| 4400-82-L-0003, 4400-82-L-3, 82-008, 82-8, NUDOCS 8202090326 | |
| Download: ML20040F543 (2) | |
Text
,
d GPU Nuclear h
g g{
P.O. Box 480 U
Middletown Pennsylvan,a 17057 i
717-944-7621 Writer's Direct Dial Number:
January 13, 1982 4400-82-L-0003 82-0C0 Office of Inspection and Enforcement Attn:
Mr. Ronald C. Haynes, Director Region 1 U. S. Nuc1 car Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Sir:
Three Mile Island Nuclear Station, Units 1 and 2, (TMI-l and 2)
Operating License Nos. DPR-50 and DPR-73 Docket Nos. 50-289 and 50-320 Inspection Report 50-289/81-30 and 50-320/81-20 This is in response to the subject Inspection Report issued December 8, 1981, and is being submitted in accordance with the provisions of the report, our letter of December 24, 1981 (LL2-81-0294) and a discussion between Mr. S. D.
Chaplin of TMI-2 Licensing with Mr. R. J. Conte, Senior Resident Inspector (TMI-2), USNRC.
In the report the Licensee was cited with one apparent noncompliance. The following is a reiteration of the citation and our response to same.
Apparent Violation (Severity Level IV)
Contrary to the requirements of Section 3.1.2 of the Licensee's NRC accepted Quality Assurance Plans for TMI-l and TMI-2, radio-active material shipping cask gasket inspections were performed on November 13, 1981 without documented acceptance criteria.
Response
The above referenced section of the TMI-2 Quality Assurance Plan states "TMI procedures, drawings and/or policies which prescribe the performance of activities important to safety shall comply with the requirements of this plan. To accomplish this, these documents shall:
a)
Include quantitative... a,d qualitative... acceptance criteria sufficient for determining that important activities have been satisfactorily accomplished."
F202090326 820201
,PDR ADOCK 05000289 PDR GPU Nuclear is a part of the General Pubhc Utihties System
7 Mr. Ronald C. Haynes 4400-82-L-0003 82-008 In this regard, the operating procedure (2104-4.111) used for the evolution
-on November 13, 1981 did provide acceptance criteria for determining whether
~
it was an acceptable seal in that it requires examination of the gasket for cracks and tears. The absence of cracks or tears, therefore,-qualifies the gasket.
If a deviation (crack or tear) from the acceptance criteria was present, further evaluation-would be required to determine the component's acceptability.
. The documentation and disposition of deviations are discussed in Section 8 of the TMI-2 Quality Assurance Plan _ (Control of Corrective Actions and Nonconformances) and controlled in QA Project Procedure TMI-15-03 (Important to Safety Material Nonconformance Report). They require the issuance and processing of a Material Nonconformance Report (MNCR) which docur.ents and ultimately dispositions the deviation as acceptable, repair-
~
able or requiring replacement. Any disposition, excluding replacement, requires an Engineering evaluation in accordance with the above referenced procedure.
Engineering would evaluate the deviation and determine the final.
disposition.
Tharefore, the acceptance criteria in the operating procedure was sufficient given the supporting analysis / disposition mechanism for situations outside the stated acceptance criteria.
The shipping cask primary lid gasket in question was inspected by both a Rad Material Coordinator (RMC) from the Waste Shipping and Disposal Group and a Q.C. Receipt Inspector. During the course of the inspection; abnor-malities in the gasket were observed and recorded by the Q.C.~ Receipt Inspector.
These abnormalities were evaluated and determined acceptable by the Waste Shipping and Disposal Group because the function of the gasket was not impaired. The evaluation and acceptance of the abnormalities was indicated on the Receipt Inspection Report. However, these abnormalities, their evaluation and disposition were not handled entirely in accordance with procedural requirements. The abnormalitic, should have been identified on a Material Nonconformance Report (MNCR) to receive Plant Engineering evaluation and disposition.
To preclude recurrence of problems of this nature all Q.C. Receipt Inspectors and all RMC personnel will receive additional instruction by February 1,1982 in receipt inspection requirements for licensed package use.
Additionally, the appropriate sections of the waste shipping cask handling procedures will be changed to clarify the evaluation process. This will be accomplished by February 26, 1982.
Sincerely, uuv I. D. Iuhill I;
Director, TMI-l cc:
L. H. Barrett V. Stello
~
B. J. Snyder th Sworn and subscribed to before me this 1L day of C, 1982.
Il
. A0 6--
dd
_ FAuttA KIMt!
c8 *
- ggetan, h:n cunty, b
W Commission E4res eust 21 IN