ML20040G030
| ML20040G030 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/10/1981 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20040G029 | List: |
| References | |
| L1L-331, NUDOCS 8202110131 | |
| Download: ML20040G030 (3) | |
Text
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Metropolitan E fison Company 6
Post Office Box '80 Middletown, Pennsylvania 17057 Writer's Direct Dial Number November 10, 1981 LlL 331 Office of Inspection and Enforcement Attn:
R. C. Ilaynes, Director Region I C. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Sir:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-?83 Inspection 50-289/81-21 This letter transmits our response to Inspection Report No. 50-289/81-21 which contained one (1) apparent violation. The attached enclosure pro-vides our response to Appendix A - Notice of Violation which is true to the best of my knowledge, information od belief.
Sincerely, f
l' kill
- 1. D.
u Director, TMI-l IIDil:CJS:vj f Attachment cc:
J. F. Stolz L. Barrett R. Jacobs Signed and subscribed to before me this 10 4 day of _ w h 1981.
I 4 m..,
Notar Public l~
UAliLA JI AA etkRY. f.Viant rubtit MIDDlH0nN EORD. Ml;F$ tit COUNTY P.tY CCMM'5510'i EFFU'Lt Rfn I/.1985 Mc6er. Pewnlwatua Nc, oatin d he' vies 8202110131 820204 PDR ADOCK 05000289 O
PDR Metropo!; tan Ed1 son Company is a Memtwr of the General Put*c Utd Les System
4 9
RESPONSE TO NOTICE OF VIOLATION IE INSPECTION REPORT 81-21 As a result of an inspection conducted on July 20-24 and 27-31,1981.and in in accordance with Interim Enforcement Policy, 45 FR 66794 (October 7, 1980),
the following violation was identified:
10 CFR 50, Appendix B, Criterion IV, states, in part, " Activities affecting quality shall be prescribed by documented... procedures... of a type appropriate to the circumstances and shall be acccmplishad in accordance with these... procedures..."; and Criterion XII states, in part, " Measures shall be established to assure that gauges (and) instruments... used in activites af fecting quality are properly controlled, calibrated and ad-justed at specified periods to maintain accuracy within necessary limits."
Three Mile Island Operational Quality Assurance Plan, Revision 9, May 2o, 1981, Appendix C, Part 2, states, in part, that the TMI QA program shall comply with the requirements of Regulatory Guide 1.33 - 1978. Regulatory Guide 1.33 - 1978, Part C, requires compliance to ANSI 18.7 - 1976.
ANSI 18.7 - 1976, Paragraph 5.2.8, states, in part, "A surveillance testing and inspection program shall be prescribed to insure that safety related...
components will continue to operate, keeping parameters within the normal bounds, or will act to put the plant in a safe condition if they exceed normal bounds.
Provisions shall be made for performing the required surveill-ance testing and inspection, including inservice inspections... control procedures shall be instituted... to assure timely conduct of surveillance tests and inspections and appropriate documentation, reporting and evaluation of the results."
Contrary to the above, the following control procedures established for the testing of safety related instruments used for surveillance testing and inservice inspection were not adequate in that:
Procedures 1302 - 14.1, " Calibrations of Inservice Inspection Instruments",
did not include instruments DH-FI-299A and 299B which, in turn, are used to measure the acceptability of Decay Removal Pumps flow per procedure 1300-3B A/B, " Decay Heat Removal Pump Functional Test".
Procedure 1302-6, " Calibration of Non-Tech Spec Instruments Used for Tech Spec Compliance", did not include the fellowing instruments:
(1)
Capacity gages for the Diesel Fire Pump Fuel Oil Tanks which, in turn, are used to assure the proper amount of fire pump diesel fuel per procedure 3303 - MI, " Fire Pump Periodic Operation".
(2)
Flow instrument FI-155 which, in turn, is used to measure adequate fire pump flow per procedure 3303-3T1, " Fire System Capability Test".
Additionally, certain of the instruments noted above had not been calibrated or had not been calibrated in a timely manner in that:
The diesel fire pu=p fuel oil tanks capacity gages and FI-155 had not been calibrated; and
4 Instrument DH-FI-299 B was last calibrated May 15, 1975 which was in excess of the 18 month interval specified in procedure 1302-14.1 for ISI related instruments.
RESPONSE
1.
Procedure 1302-14.1 " Calibration of Inservice Inspection Instruments" will be revised by 1/1/82 to assure that DH-FI-299A dqp 299B are periodi-cally calibrated.
Instrument DH-FI-299B will be' calibrated prior to the next required performance of the subject, procedure.
- ,t
. +,.,
2.
Procedure 1302-6, " Calibration of Non-Tech Spec Instruments used for Tech Spec Compliance".
(a) L1-213 and 214 are capacity gauges used on the Diesel Fire Pump Fuel Oil Tanks to assure the proper amount of diesel fuel per 3303-MI,
" Fire Pump Periodic Operation".
There is presently no acceptable means to verify the proper calibration of this type level gauge.
It would te necessary to fill and drain the fuel oil tanks in order to calibrate the level gauges which is not possible with the present p-ping and fuel oil tank configuration.
The fuel oil tanks are scaled and have no means available to drain them.
k'e will look at alternative means of verifying the level in the fuel oil tanks which may include level sight glasses or a different type of level indicating device. Whichever means is used the new devices will be added to procedure 1302-6 " Calibration of Non-Tech Spec Instru-ments used for Tech Spec Compliance" to periodically asstre accurate indication of fuel oil capacity.
(b) Subject Procedure will be revised by 1/1/82 to include the calibration of FI-155 which is used to measure fire pump flow per procedure 3303-3Y1,
" Fire System Capability Test".
The flow instrument will be calibrated prior to the next performance of 3303-3Y1 which is scheduled for 1984.
._