ML20064M654

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Responds to NRC Re Violations Noted in IE Insp Rept 50-289/82-21.Corrective Actions:Safety Evaluation for Safety Valve Position Indications Revised to Include New Scope of Work
ML20064M654
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 01/20/1983
From: Hukill H
GENERAL PUBLIC UTILITIES CORP.
To: Haynes R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20064M606 List:
References
5211-83-021, 5211-83-21, NUDOCS 8302150603
Download: ML20064M654 (2)


Text

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GPU Nuclear Corporation 0s.

U Guclear m'1smesss48o Middletown, Pennsylvania 17057 717 944-7621 TELEX 84-2386 Writer"s Direct Dial Number:

January 20, 1983 5211-83-021 Mr. R. C. Haynes Region I, Regional Administrator 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 Response to Inspection Report 50-289/82-21 This letter is submitted in response to the subject report, Notice of Violation dated December 9, 1982. Attachment 1 contains our reply and specific corrective actions in accordance with the provisions of 10 CFR 2.201. This response is provided within the 10 day extension period provided after consultation with the Senior Resident Inspector, Mr. R. Conte.

Sincerely, H. D. Kill Director, TMI-l HDH: CJS:vj f Enclosures cc: Mr. R. Conte Sworn and Subscribed to before me this 20th day of January , 1983.

An m .

Nota Public

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ATTACHMENT I RESPONSE TO INSPECTION REPORT 50-289/82-21 NOTICE OF VIOLATION As a result of the inspection conducted on October 5, 1982, through November 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 50.59.(b) requires, in part, that a record be maintained of the written safety evaluation which provides the basis for the determination that a change to the facility as described in the safety analysis report does not involve an unreviewed safety question.

Contrary to the above, on November 8, 1982, a written safety evaluation was not available for installation of mechanical aspects for the reactor coolant system safety valve position indications (differential pressure elbow taps and acoustic monitor per GPU Nuclear Engineering Change Memorandum No. 057, Revision 3, dated September 17, 1980). The installation is a change to the facility as described in the safety analysis report.

This is a Severity Level IV Violation (Supplement I).

RESPONSE

1. Corrective Actions Taken and Results Achieved.

GPU has reviewed the history of Engineering Change Memorandum (ECM) No. 057, Revision 3, dated September 17, 1980. It appears from this review that a scope change occurred in Revision 3, which changed a portion of the ECM 057 package to Nuclear Safety Related by virtue of relocating the condensing pots. The elbow pressure taps and the acoustic monitor were not a part of ECM No. 057 but were part of ECM Nos 046, Rev. O and 011, Rev. 1 respectively. Safety evaluations were and are available for ECM's 046 and 011. Engineering personnel in the field apparently did not review in detail the original safety evaluation for ECM 057 when Rev. 3 was issued, even though it did change its classification to " Nuclear Safety Related". In order to correct this problem the safety evaluation has been revised to include the new scope of work.

2. Corrective Steps Which Will Be Taken to Avoid Furthe- Violations In order to prevent recurrence, a memo has been sent to Engineering Supervisory Personnel addressing this particular concern and reminding them of their obligation to carefully review the original safety evalua-tions to ensure that scope of work changes, if any, are duly reflected in the safety evaluations. This memo was issued January 14, 1983.
3. Date When Full Compliance Will Be Achieved Full compliance was achieved December 6, 1982.

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