ML20041B863
| ML20041B863 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/11/1982 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20041B860 | List: |
| References | |
| 82-001, 82-1, NUDOCS 8202250274 | |
| Download: ML20041B863 (3) | |
Text
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GPU Nuclear G'
eM P.O. Box 480 Middletown, Pennsylvania 17057 717-944-7621 Wnter's Direct Dial Number:
January 11, 1982 82 - 001 Office of Inspection and Enforcement Attn:
R. C. llaynes, 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 Inspection 50-289/81-27 This letter transmits our response to Inspection Report No. 50-289/81-27 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 and belief.
Sincerely, e
1.
D. I kill Director, TMI-l HDH:WJM:vj f g
Attachment cc:
J. F. Stolz L. liarrett R. Jacobs Signed and subscribed to before me thisli day of k g311{LL 1982.
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PDR GPU Nuclear is a part of the General Pubhc Utihties System J
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RESPONSE TO NOTICE OF VIOLATION IE INSPECTION REPORT 81-27 As a result of an inspection conducted on October 4-7 and 9, 1981, and in accordance with Interim Enforcement Policy, 45 FR 66754 (October 7, 1980),
the following violation was identified:
10 CFR 50, Appendix B, Criterion XVII, states in part " Sufficient records shall be maintained to furnish evidence of activities affect-ing quality..."
Three Mile Island Operational Quality Assurance Plan, Revision 9, dated May 28, 1981, Appendix C, Part 1, states, in part, that the TMI QA Program shall comply with requirements of ANSI 18.7-1976.
ANSI N18.7-1976, " Administrative Controls and Quality Assurance of the Operational Phase of Nuclear Power Plants", paragraph 5.2.7, states, in part, "...Means for assuring quality of maintenance activities...and measures to document the performance thereof shall be established... Measures shall be established and documented to identify the inspection and test status of items to be used in maintenance... activities..."
Contrary to the above on October 7, 1981, the results of five TMI Unit 1 maintenance activities and post-maintenance testing had not been adequately documented in the maintenance records.
Examples of these incomplete records are detailed in the attached inspection report.
This is a severity level VI violation (Supplement 1)
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) correc-tive 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 anended, this response shall be submitted under oath or affirmation. Where good cause is shown, consideration will be given to extending your response time.
s.
Response
Licensee's review indicated that the documentation problems identified by the NRC varied according to personnel that were documenting maintenance work. Promptly after the NRC exit on Inspection 81-27, the Manager-Plant Maintenance TMI-l instructed Maintenance Managers and Lead Foreman of the NRC concern with the documentation of certain maintenance work. These individuals were directed to ensure that documentation in work packages was explicit in what work was performed and the post-maintenance testing results.
In addition, Lead Foremen were instructed to inform individual foremen under their supervision of these requirements. The guidance of the Manager-Plant Maintenance TMI-l was later reinforced by a memorandum issued in mid December to all Maintenance Managers, Supervisors and Fore-men.
Since issuance of additional guidance, Maintenance Managers have been instructed to pay particular attention to the Resolution Description section of the Job Tickets during their review of completed Job Tickets for adequacy of documentation of work performed and post-maintenance test results. This review has demonstrated improvement in documentation to ensure compliaace with documentation requirements.
s Licensee's completed actions (verbal guidance, written guidance and manager verification of results in completed job packages) constitute our complete corrective action to this item of non compliance.
s-I 0A
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