ML20082G957

Responds to NRC Re Violations Noted in Insp Rept 50-289/91-09 on 910512-0622.Corrective Actions:Carbon Steel Yarway Valves Hold Tagged & Incorrect Nameplates Replaced by Yarway on 910814-15

ML20082G957
Person / Time
Site:	Three Mile Island
Issue date:	08/19/1991
From:	Broughton T GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
C311-91-2094, NUDOCS 9108220172
Download: ML20082G957 (4)

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l GPU Nuclear Corporation G i u Nuclear

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Middletown, Pennsylvania 17057 0191 717 944 7021

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TELEX 84 2386 Writer's Direct Dial Numtser:

(717) 948-8005 August 19, 1991 C311-91-2094 U. S. Nuclear Regulatory Commission Attn:

Document Control Desk Washington, D.C.

20555 Gentlemen:

Subject:

Three Mile Island Nuclear Station, Unit I (THI-1)

Operating License No. DPR-50 Docket No. 50-289 Response to Notice of Violation in inspection Report 91-09 This letter transmits GPUN's response to the Notice of Violation in Appendix A to Inspection Report 91-09.

Sincerely, T. G. Bro /

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ughton Vice President & Director, TMI-l WGH:

Attachment cc: Administrator, Region 1 1MI-l Senior Project Manager TMl-1 Senior Resident inspector 9108220172 910819 POR ADOCK 05000289 O

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GPU Nuclear Corporation as a subsidiary of General Pubbe UtJitM Corporation

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METR 0POLIfAN EDISON COMPANY t

JERSEY CENTRAL POWER AND LIGHT COMPANY PENNSYLVANIA ELECTRIC COMPANY l

GENERAL PUBLIC UTILITIES NUCLEAR COPR0 RATION Three Mile Island Nuclear Station, Unit 1 (1MI-1)

Operating License No. OPR-50 Docket No. 50-289 l

Response to the Notice of Violation in Inspection Report 91-09 This letter is submitted in response to the Notices of Violation in Inspection Report 91-09, Routine Monthly inspection for the period May 12 through June 22, 1991 for TM1-1 dated July 19, 1991. All statements contained in this response have been reviewed, and all such statements made and matter set forth therein _are true and correct to the best of-my knowledge.

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T. G. Broughton Vice President and Director, THI-l l

l Signed and sworn before me this 19th day of August

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C311-90-2094 Attachment Page 1 of 2 Notice of Violation 10 CFR 50, Appendix B, Criterion XF, requires that measures shall be established to ass',tre that conditions adverse to quality, such as deficiencies, deviations, defective material and equipment and non-conformances are proaotly identified and corrected.

GPUN's accepted QA program, implemented )y Administrative Procedure 1000-ADM-7215.01,

• Material Non-Conformance Reports and Receipt Deficiency Notices" requires the licensee to initiato action to assure that nonconforming material is not inadvertently used through use of QC hold tags.

Contrary to the above, the licensee failed to initiate action to assure that non-conforming material was not inadvertently used.

On June ll, 1991, the inspector identified approximately 155 mislabeled carbon steel Yarway valves that were not QC hold tagged.

GPUN Response Backaround Mislabeled stainless steel valves were aricinally discovered during engineering review of material grade ufferona, (316 vs. 316L) identified at weld fit up inspection.

Engineering and Quality Assurance researched the problem and found that-all-sizes of stainless steel-Yarway valves in TMl stock were mislabeled. MNCR 91-2016 was written to address all-54 stainless steel valves (5 different sizes) that TMl had received.

i Engineering review and research of the MNCR found that, in' addition to stainless steel valves, carbon steel valves provided by Yarway were also mislabeled.

The engineering disposition of the MNCR addressed both stainless-steel and the carbon steel valves. No stainless steel valves had been-installed, but some carbon steel valves had been installed in various plant

systems. The carbon steel valves installed were evaluated ~to be acceptable as is. The pressure temperature rating of the carbon steel Yarway valves significantly exceeded design requirements of al1~ carbon steel system applications at TMI, and therefore posed no safety concern.

The engineering disposition to the-MNCR required Yarway to retag_the remaining <

-stock of stainless steel and carbon steel valves-with proper nameplates; and the subject valves were to be kept on hold until retagged.: However, Quality Assurance personne1Lfailed to place the carbon-steel valvest on hold as-required by the GPUN Material Nonconformance: procedure 1000-ADM-7215.01. The stainless steel valves had previously been placed on QA hold. ;The cause of this violation is that Quality Assurance personnel failed to recognize and act on the increased scope of the MNCR and affix. hold tags-to the carbon steel-valves pending retagging with new nameplates by Yarway.

Corrective Actions Taken and Results Achieved immediate corrective steps were taken-to hold tag the--carbon steelLYarway;

- valves. Yarway replaced the incorrect; nameplates on-August 14-15,-1991.

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0 C311-90-2094 Attachment Page 2 of 2 Supplier Corrective Action Request was sent to Yarway (SCAR 91-002) which has been addressed and clo;ed.

The cause of the error was attributed to incorrect nameplate drawings. The valve pressure / temperature ratings changed in 1977 from tables in ASME 111 to ANSI B16.34.

The design and manufacturing requirements for the valve did not change, llowever, the nameplate drawings were not updated to reflect subsequent changes in pressure temperature ratings

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of the valves.

To assess whether the failure to hold tag the ccrbon steel valves on hold was isolated or indicative of a programmatic concern, Quality Assurance requested that an evale.> tion of the MNCR arogram for the specific problem identified by the NRC inspsetor be added to t1e scope of QA corrective action audit, S-1M!-91-15.

As a result, an additional 30 MNCR's were-reviewed and no similar cases were identified.

it is concluded that the addition of scope during the disposition phase of the MNCR is unusual, and that the specific problem found was an isolated incident and no programmatic corrective action is warranted.

fatt.ggtive Actions to Prevent Recurrence As previously stated, the addition of scope during the disposition phase of the MNCR is unusual.

The incident has been reviewed with QA personnel involved in the MNCR process to heighten awareness for " expanded scope dispositions".

Date of Full Compliance Corrective action was completed as of August 16, 1991 when Yarway replaced the nameplates on the carbon steel valves.

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