ML20062L772
| ML20062L772 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/29/1982 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20062L752 | List: |
| References | |
| 5211-82-179, NUDOCS 8208190237 | |
| Download: ML20062L772 (3) | |
Text
.
GPU Nuclear h-gg g{
P.O. Box 480 Middletown, Pennsylvania 17057 717-944-7621 Wnter's Direct Dial Number:
July 29, 1982 5211-82-179 Office of Inspection and Enforcement Attn:
R. C. Ilaynes Region I, Regional Administrator U. S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Sir:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Response to Inspection Report 50-289/82-07 This letter is submitted in response to the subject report, Notice of Violation, dated July 1, 1982. contains our reply and specific corrective actions in accordance with the provisions of 10 CFR 2.701.
Sincerely, D. Ilu ill Director, TMI-l llDil: RAS :yj f Enclosures cc:
Mr. R. Conte Sworn and Subscribed to before me this 29th day of July
, 1982.
ar DARLA JEAN EERRY. NOTARV PUBilC MIDDtiTOWN BORD. DAUPHIN COUNTY MY COMMISSION IXPIRES JUNE 17.1965 Member. Pennsylvama Association of Retanes 8208190237 820812 PDR ADOCK 05000289 G
PDR GPU Nuclear is a part of the General Pubhc Utihties System
I l
ATTACHMENT 1 Response to Inspection Report 50-289/82-07 Notice of Violation as a result of the inspection conducted on May 11, 1982, through June 8, 1982, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C),
47 FR 9987 (March 9, 1982), the following violation was identified.
10 CFR 50, Appendix B, Criterion V, and the NRC approved Operational Quality Assurance Plan, Revisfor 9, May 28, 1981, Section 3.1, require in part that activities affecting quality be prescribed by and accomplished in accordance with instructions or drawings of a type appropriate to the circumstances.
Contrary to the above, as of June 4, 1982, a safety related modification (designated task LM-9, Relocation of Pressurizer Level Transmitters and j
Transmitter Supports) was not accomplished in accordance with drawing B-308-854, Revision TA-0 Certain transmitter sensing lines did not have a continuous downward slope at 1 inch vertical per I foot horizontal as required i
by the drawing.
I j
This is a Severity Level V Violation (Supplement I).
i 1
i l
l l
4 i
i b
Res'poase
Background
The subject task was installed by Plant Maintenance during late 1979 and early 1980. The level instruments were calibrated in December 1981. The subject task was turned over to QC for final walkdown inspection in January 1981. The modification was subsequently reviewed by the NRC on or about the first week in June 1982 and deficiencies were identified that were not documented in the turnover package. A subsequent inspection by QC on 6-10-82 confirmed the NRC's findings.
Additionally, during the time period of interest, modifications were accomplished under Rev. 7,8 and 9 of the OQA Plan and existing various revisions of plant modification procedures. As of January 1982, a new revision of plant administrative procedure AP-1043 was put into place to better define and control the installation, inspection, testing and turnover.of modifications to operations.
(1) Corrective steps which have been taken and the results achieved.
With respect to the specific finding, the criteria for slope required on the transmitter sensing lines was evaluated and determined to be a minimum of k inch vertical per 1 foot horizontal. Field Change Request C-004146 reflects this change to drawing B-308-854. Additionally, Job Ticket C8815 was completed, which corrected the damaged tubing supports which had allowed the tubing to sag.
The subject lines slope is now greater than h inch vertical per 1 foot horizontal, and therefore meets the criteria of FCR C-004146.
With respect to the implication of the adequacy of other modifications installed and inspected in the time period of interest (1979 thru 1981) Quality Control has identified eight (8) additional modifications involving instrument tubing and conducted sampling reinspection of three (3) of those to determine if similar problems exist. The result of this review is that there did not exist conditions representing nonconformance to the design requirements.
(2)
Corrective Steps Which will be taken to avoid further violations.
Since the time period involved, plant procedure AP-1043 Rev. 3 has been issued to provide improved controls for installation, inspection, testing and turn-over l
of modifications to operations. The practices of inspecting these modifications I
have evolved with the modification program and currently provide adequate confidence to assure design requirements are implemented or addressed by engineering.
No further action is warranted.
(3)
Date when full compliance will be achieved.
Full compliance has been achieved as of July 21, 1982.
i l
l
(
I l
l
m l
ATTACHMENT 1 Response to Inspection Report 50-289/82-07 Notice of Violation As a result of the inspection conducted on May 11, 1982, through June 8, 1982, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C),
47 FR 9987 (March 9, 1982), the following violation was identified.
10 CFR 50, Appendix B, Criterion V, and the NRC approved Operational Quality Assurance Plan, Revision 9, May 28, 1981, Section 3.1, require in part that activities affecting quality be prescribed by and accomplished in accordance with instructions or drawings of a type appropriate to the circumstances.
Contrary to the above, as of June 4,1982, a safety related modification (designated task LM-9, Relocation of Pressurizer Level Transmitters and Transmitter Supports) was not accomplished in accordance with drawing B-308-854, Revision IA-0.
Certain transmitter sensing lines did not have a continuous downward slope at 1 inch vertical per 1 foot horizontal as required by the drawing.
This is a Severity Level V Violation (Supplement I).
.