ML20040G034
| ML20040G034 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/21/1981 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20040G029 | List: |
| References | |
| L1L-369, NUDOCS 8202110141 | |
| Download: ML20040G034 (3) | |
Text
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Metropolitan Edison Company
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Post Of fice Box 480 Middletown, Pennsylvania 17057 Writer's Direct Dial Numtwr December 21, 1981 L1L 369 Office of Inspection and Enforcement Attn:
R. C. Haynes, Director Region I U. 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. 50-289 Supplemental Response to Inspection 50-289/81-21 This letter supplements and clarifies our response to Inspection 81-21.
The information contained in the attached Supplemental Response.is true and correct to the best of my. knowledge and belief.
Sincerely,
.h. M t
/ (/
H. D. H ill Director, TMI-l HDil:CWS:vj f Attachment cc:
J. F. Stolz R. Jacobs D. Haverkamp Signed and subscribed to before me this ) /
day of hop /yy>b
, l' 81.
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. Not - y ublic FAgdA JOY LU8 RECT - Natary Pubhc
- Mddktewn, Daugh... County, Pa Wy Ccagnissic.a hpires Agust 29, 1933 8202110141 820204 PDR ADOCK 05000289 e
PDR Metropobtan E'dson Company is a Member of the G?nera! Pubhc Unt;es System i
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Supplemental Response to Inspection 50-289/81-21 i
Violation Subpart A Procedure 1302 - 14.1, " Calibration 'of Inservice Inspection Instruments",
ldid 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".
Revised Response to Violation Subpart A 1.
Corrective Steps Taken to Date:
CH-FI-299A and 299B were calibrated on 11/14/81. A change to procedure 1302-14.1 has been prepared and submitted for approval. The change will add DH-FI 299A and 299B to the calibration program. The procedure change is expected to be approved by 1/1/82. The " Decay Heat Removal Purp Functional Test" procedure-1300-3B A/B will be conducted prior to startup..
2.
Date when full compliance will be achieved:
Full compliance is expected by 1/1/82 when the changes to SP 1302-14.1 are approved.
3.
Steps taken to Avoid Further Violations IST Procedures were reviewed to assure instruments used to_ verify operability of IST equipment were included in 1302-14.1.
A revision was made to 1302-14.1 to correct identified discrepancies.
The procedure governing biennial procedurereview.(AP_100lK " Periodic Review of Procedures") will be modified to provide guidance to reviewers (procedure owners). This guidance will specify that where Surveillance Procedure recuirements exist for use of instruments to determine "Oper-ability', procedure owners should assure that Surveillance Procedure requirements also exist for calibration of those instruments.
AP 1001K will be modified by 4/1/82.
t Violation Subnart 3 Procedure 1302-6, " Calibration of Non-Tech Spec Instruments Used for Tech Spec Compliance", did not include the following instruments:
(1)
Capacity gages for the Diesel Fire Pump Fuel 011 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 3303-3Y1, " 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:
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The diesel fire pump fuel oil tanks capacity gages and FI-155 had not been calibrated;:and Instrunent DH-FI 299B 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.
Revised Response to Violation Subpart B t
1.
Corrective Steps Taken to Date:
A change to procedure 1302-6 " Cal'ibration of Non-Tech Spec Instruments used for Tech Spec Compliance," has been submitted for approval to include LI-213 and LI-214. App'roval is expected by 1/1/82.
Calibration of LI-213 and LI-214 is also expected to be complete by 1/1/82. Due to '
the design of these level instruments, and the difficult 1y of performing the calibration, modifications may also be made to replace these instruments with a design more easily calibrated. We have reviewed procedure 3303-3Y1 7
" Fire System Capability Test" and have deternined that procedure 33303-A2
" Fire System Main Header Flush and Loop Test" more than s'atisfies the 3 year flow test requirement of 3303-3Yl.
3303-A2 is conducted bn>a 12 month s schedule and uses portable test equipment which is calibrated!jdEt prior 'to Based on this, we plan to delete procedure-3303-3Y1 which's~pecifies the \\
d use.
use of FI-155.
FI-155 will not be included in the instrument' calibration program under procedure 1302-6.
For completeness, a change to procedure ~3303-
~
A2 uill be made by 2/1/82 to note that it satisfies the'3 year flow test
' ~
requirement.
2.
Date When Full Compliance Will Be Achieved:
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Full compliance is expected by 1/1/82 when the instruments are.
calibrated and changes to SP 1302-6 are approved. With respect to j
71-155 we are now in full compliance.
3.
Steps Taken to Avoid Further Violations:
See response to A.3 above.
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