ML20077K143

Forwards Suppl Response to NRC Ltr Re Violations Noted in Insp Rept 50-289/94-80-01.Corrective Actions:Tmi Plant Maint Has Continued in-depth Review of Cancelled Preventive Maint Activities

ML20077K143
Person / Time
Site:	Three Mile Island
Issue date:	12/27/1994
From:	Broughton T GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
C311-94-2340, NUDOCS 9501100202
Download: ML20077K143 (3)

Text

i 3, Nuclear GPU Nuclear Corporatic.,

".':4 nee"*

s Middletown, Pennsylvania 17057-0480 (717) 944-7621 Writer's Direct Dial Number:

(717) 948-8005 December 27, 1994 C311-94-2340 i

U.S. Nuclear Regulatory Commission l Attn: Document Control Desk j Washington, DC 20555 l i

Subject:

Three Mile Island Nuclear Station, Unit 1 (TMI-1)

Operating License No. DPR-50 Docket No. 50-289 Supplemental Reply to Notice of Violation (N0V) 94-80-01 Enclosed is the GPU Nuclear supplemental reply to Notice of Violation 94-80-01 which cited GPU Nuclear for failing to comply with the requirements of Technical Specification 6.8.1 when deferring / cancelling scheduled preventive maintenance. The initial response to NOV 94-80-01, T. G. Broughton to DCD, C311-94-2312, was submitted by letter dated November 18, 1994. Please contact J. S. Schork, TMI Licensing at (N 7) 948-8832 should you have any questions regarding this response.

Sincerely, M .

-h T. G. Broug ton Vice President and Director, TMI JSS Attachment cc: Region I Administrator THI-1 Senior Project Manager TMI Senior Resident Inspection 9501100202 ",41227 /

PDR ADOCK 05000289 U t/

PDR GPU Nuclear Corporation is a subsidiary of General Pubhc Utikties Corporation

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/ Notice of Violation 94-80-01 I i

During'an NRC inspection conducted on' August 29 to September 16, 1994, a violation l of NRC requirements was identified. In accordance with the " General Statement of- 1 Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:

Technical Specification (TS) step 6.8.1 states in part, that written procedures shall be established and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2,- ,

February 1978. l Appendix A, Procedures for Performing Maintenance, Regulatory Guide 1.33,-

Revision 2, February 1978, states in part, that preventive maintenance  ;

schedules should be developed to specify lubrication schedules, and inspection of equipment. j Administrative Procedure 1070, TMI-1 Maintenance Plan, Revision 8, written  !

to comply with TS 6.8.1, established the preventive maintenance (PM) program and schedule as follows:  ;

Step 3.1.2.1 definos preventive maintenance tasks as actions taken on ,

a routine basis to restore part or all of the failure resistance of unfailed equipment or systems, initiated as a function of time or production, regardless of the actual condition of the equipment or system.

Step 4.1.3.2 states that preventive maintenance tasks shall be initiated as part of the automated generation maintenance system.

Step 4.2.3.0 states that the task performance interval may be adjusted  :

as a result of assessing the adequacy of the PM program and also as a  !

result of reliable performance of equipment / component or satisfactory performance of PM tasks.

Contrary to the above, on August 30, 1994, TMI-1 personnel had deferred / cancelled several PMs on safety related motor operated valves without proper technical justification or assessment of the adequacy of the '

PM program.

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

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/'- GPU' Nuclear Supplemental Response to the' Notice of Violation

- GPU Nuclear agrees the violation occurred as stated in the notice of violation and '

has previously submitted a response which describes the actions taken to ensure a recurrence of the violation does not occur. The purpose of this supplemental ,

response is to provide additional-information regarding the review of previously deferred / cancelled preventive maintenance tasks. ,

Subsequent to the OSTI inspection TMI Plant Maintenance has continued an in-depth  ;

review of deferred / cancelled preventive maintenance activities. The purpose of the review is to ensure that the scope of deferred and cancelled PMs is clearly .

understood, that deferrals are thoroughly analyzed, technically justified and properly documented and that long-term corrective action addresses the full extent of the issue. GPU Nuclear anticipates completing this review by the end of the i 1st Quarter of 1995.  !

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