ML20070N801
| ML20070N801 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/04/1994 |
| From: | Broughton T GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| C311-94-2065, NUDOCS 9405090222 | |
| Download: ML20070N801 (3) | |
Text
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0 GPU Nuclear Corporation U
Gar aovte 44' souta P.O. Box 480 Middletown, Pennsylvania I7057-0480 (717) 944-7621 Writer's Direct Dial Nurnber:
(717) 948-8005 May 4, 1994 C311-94-2065 U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555
Subject:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Response to Notice of Violation 94-02-02
Dear Sirs:
Your letter of March 30, 1994, transmitted Inspection Report 94-02 which contained two Notice of Violations.
This letter contains our response to Notice of Violation 94-02-02.
The Notice of Violation states that records required by Commission regulations or license conditions were not complete and accurate in all material respects.
Pursuant to the provisions of 10 CFR 2.201, provides the GPU Nuclear response to the Notice of Violation.
Sincerely, fj % ilm T. G. Bro ton Vice President and Director, TMI JSS/ emf Attachment cc:
M. G. Evans - TMI Senior Resident inspector R. W. Hernan - Senior Project Manager T. T. Martin - NRC Regional Administrator, Region I p-
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n 9405090222 940304 L
{DR ADOCK 05000289 I
-l PDR GPU Nuclear Corporabon is a subsidiary of General Pubhc UtAties Corporation l
ATTACHMENT 1 l
C311-94-2065 NOTICE OF VIOLATION RESPONSE l
During an NRC inspection conducted on January 18, 1994 - February 28, 1994, two violations of NRC requirements were identified.
Notice of Violation 94-02-02 states:
10 CFR 50.9(a) requires that information required by statute or by Commission's regulations shall be complete and accurate in all material respects.
Technical Specification 6.8.la states, in part, that written procedures shall be implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Revision 2, February 1978, Appendix A, identifies safety-related activities that should be covered by written procedures.
Item 1.h. under Administrative procedures identifies log entries as an activity that should be covered by procedures.
l Contrary to the above, the licensee determined that records required to be maintained by commission regulations or license conditions were not complete and accurate in all material respects.
On January 27, 1994, on the 7 a.m. to 3 p.m. shift, the auxiliary operator performing the Outbuildings Tour Log, recorded two readings for the River Water Fire Service Diesel Building without entering the building to perform tae readings.
This error was material in that it evidenced that checks had been made when they had not.
Response
GPU Nuclear acknowledges that the violation occurred as stated in the notice of violation. At the time of discovery of the event by GPU Nuciear, GPU Nuclear informed the NRC and conducted an investigation. The investigation confirmed that an Auxiliary Operator (A0) had entered log readings on the 7-3 shift on January 27, 1994 for FS-P-3 (Fire Service Pump
- 3) without entering the FS-P-3 building.
The A0 entered the FS-P-3 readings on the Outbuildings Log while he was in the Screen house in anticipation of what the readings were going to be when he entered the I
FS-P-3 Building.
When the A0 exited the Screen House, he was told to pick up another operator immediately and turnover the truck to the operator.
The Outbuildings operator then ate dinner and was given other duties for the rest of his shift.
The Outbuildings operator could not finish the l
Outbuildings log readings and that task was turned over to another operator with no instructions to validate the FS-P-3 log entries.
The event was identified on January 28, 1994 by GPU Nuclear when during an i
investigation into a reported problem with the lock on the door of the FS-P-3 building that prevented taking of FS-P-3 readings on the 3-11 shift on January 27, 1994, the A0 in question informed the daylight Shift Supervisor that he had entered the FS-P-3 log readings in the Outbuilding Log without entering the building on January 27, 1994.
The A0 repeated his statement during a subsequent interview on January 28, 1994, and acknowledged that he had received documented training on the proper way to take readings.
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ATTACHMENT 1 C311-94-2065
'The cause of this event is personnel misconduct.
The A0 failed to perform his assigned job in accordance with specific procedural requirements and docu'mented training.
GPU Nuclear took the following corrective actions in response to this event:
1.
The A0 involved received disciplinary action.
2.
It was verified that the FS-P-3 readings had been taken for the 11-7 shift on January 26/27, 1994 and on the 11-7 shift on January 27/28, 1994.
3.
The activity records for the A0 that was disciplined were reviewed with respect to operator readings and vital door access for a three month period.
No additional log keeping problems were identified.
4.
All TMI Auxiliary Operators were personally informed by the Plant Operations Director of his expectations on the proper way of doing business which included Tours, Log Keeping and filling out the Operators Log sheets and a reading of step 4.1.2.1.a.5 of Administrative Procedure 1016, " Operations Surveillance Program ",
which states "Information should be recorded on the log concurrently with when it is obtained.
In no case shall information be entered prior to or in anticipation of the observation or event". At the completion of each discussion with each A0, the operators were asked if they knew of any logging problems.
No additional logging problems were identified.
All actions have been completed as of the date of this response.
GPU Nuclear believes the actions taken provide reasonable assurance that a similar event will not occur in the future.
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