ML20066A841
| ML20066A841 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/26/1990 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| C311-90-2154, NUDOCS 9101040143 | |
| Download: ML20066A841 (4) | |
Text
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OPU Nuclear Corporation A Muclear
- => e-Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2380 Writer's Ofrect 0181 Number:
C311-90-2154 U.
S.
Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555
Dear Sir:
Three Milo Island Nuclear Station, Unit (TMI-1)
Operating Licenso No. DPR-50 Docket No. 50-289 Response to Notice of Violation in Inspection Report 90-15 r
Enclosed is GPUN's response to the Notice of Violation in Appendix A to Inspection Report 90-15.
This responso also addresses IR 90-18, which includos a third example of the violation cited in IR 90-15 and provided a revised date for responding.
Sincerely, s
k s.
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- 11. n. I u,ill Vice President and Director, TMI-1 HDil/MRK Sworn and subscribed to before a this jk.#h Attachment day o.f /r /ft?nh t 1990.
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No%' Public
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MW3 cc:
Region I Administrator, NRC t-1
'::orW Director, Project Directorate I/4, NRC
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Senior Project Manager, TMI-1, NRC Senior Resident Inspector, TMI-1, NRC 9101040143 901226 PDR ADOCK 05000289 g
PDR i 2 ' I.b' ].
GPU Nuc' ear Corporaton is a subsidiar> ct General Pubhc Utsities Corporaton
1 C311-90-2154 j
Attachment l
Page 1 of 3 i
Notice of Violation Technical Specification 6.8.1 requires that written procedures I
shall be established and implemented for surveillance and. test activities of equipment that affects nuclear safety and for maintenance that can affect the performance of safety-related i
equipment.
Contrary to the abovet a.
On August 22, 1990, the licensee failed to adequately establish Surveillance Procedure (SP) - 1303. 4.1 l
Stop 8.6 did not provide
-[ sic] adequately establish the-initial conditions for testing RPS response.
The step failed to reset the bistable after testing the previous function.
This j
-could have resulted in a Reactor Protection System not being fully tested.
b.
On September 10, 1990, the licensee-failed to adequately implement Preventive Maintenance Procedure E-18, " Battery Chargers-Annual Inspection."= The-prerequisite to perform the specific checklist required by stop 1.1.1. was not accomplished.
c.
As a third example, during the performance of E-18 described in b. above, the hand written guidance used was different from the procedure and as a result, step 6.6 was not performed as written (IR 90-18).
This is a Severity Level IV Violation (Supplement I).
GPUN Response-I.
Admission'or denial of the violation-GPUN accepts the above violation.
II.
Reasons for the violation We believe that the procedural inadequacies and l
implementation problems cited occurred:primarily as a result of oversight on the part of the procedure writer and those-
-who reviewed and approved the procedures, and partly because of Jnadequate communication.
-a.
The example-of the violation regarding the-failure to' include a reset step in SP 1303-4.1: occurred-because of 4
I i
C311-90-2154 Attachment Page 2 of 3 an oversight on the part of the procedure writer.
Each 1
of the other-reset steps were included.
However, we did not achieve the level of detail intended without-this-step.
Therefore, we accept this example as cited in the violation.
- b. Several_ maintenance procedures contain a generic i
requirement to verify the operability of the redundant:
string prior to working ~on-components in a safetyLsystem.-
This requirement is accomplished by operations personnel e
who complete the verification.
Redundant string operability verification is controlled by switching and 4
tagging procedure AP 1002, which fully meets the intent of this generic requirement.
However, the wording of 2
this step as it refers to a " specific checklist" to verify operability of the redundant-string is recognized as inaccurate terminology.
The misunderstanding over the procedure step in E-18 that refers to a " specific checklist" resulted because of inadequate communications in that maintenance personnel were not made aware of how the requirements of this step are being met.
- c. The battery charger re-powering incident occurred, in part, because of' inadequate communications.between.the job supervisor and the-technician performing the work.
The job supervisor had intended the written steps to-indicate only that battery charger DC power be applied before AC power.
It was not his intention that a different breaker closing sequence to be taken into the
[
field-and used in violation of the procedure.
The different breaker closing sequences were technically sound, as acknowledged in IR 90-15, and could have been allowed by the procedure.. This misunderstanding would not have resulted_in the' violation-if the procedure (E-18, Rev-9) had allowed the flexibility where appropriate.
(
III. Corrective steps which have been taken and the results nchieved l
SP 1303-4.1 was revised before the next scheduled.
L performance to include the specific bistable resets identified lin the notice of violation.- This completes the required action to resolve example "a" cited above.
In response to example "c" of the violation, the Plant Materiel Director has re-emphasized adherence to the-
' requirements of AP 1001G when-procedure steps.cannot be followed inLa memorandum dated November 13, 1990 to all-
. maintenance personnel.
The~ memo also re-emphasizes that an
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C311-90-2154 Attachment l
Page 3 of 3 4
individual who believes-a job should be done in some way-l different from that specified by the procedure should change the procedure prior to performing the work.
The memo specifically states that= procedural compliance is a-requirement.
IV.
Corrective steos which will beLtaken to avoid furthEr violations E-18 and the other procedures containing the ambiguous reference to a " specific checklist" will-be revised as part of the procedure improvement program.- Until such time as E-18 is revised to more adequately reflect re-powering _
~
requirements,.the current procedure operating sequence is technically correct and will continue to be used.-
n In response to example "b"
of the violation,__the TMI-1 Maintenance Procedure Writer's Guide addresses the-issue of r
safety system redundant string verification prior to i
maintenance.
As individual procedures go through the improvement process, they are being revised to remove the i
ambiguity of the reference to a " specific checklist."
The intent of this_ procedure step, along with the changes to improve it, have been documented by a memorandum dated September 19, 1990 and will-be discussed-with all' foremen and crafts personnel.
Operations personnel are aware of their responsibilities for verification of redundant string operability and have been performing.this function i
correctly.
Therefore, we do not.believe that dedicated efforts in addition to the ongoing procedure-improvement-
[
program are warranted to revise all of the affected I
procedures.
V.
Date of Full Comoliance l
Although all'of the procedures containing.the ambiguous step-
-that refers to a " specific checklist" may not be revised until completion of the procedure improvement-program, all maintenance personnel will have been instructed regarding the acaning of this step sufficiently to compensate for the ambiguity-by January, 1991.
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