ML20096C355
| ML20096C355 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/24/1984 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 5211-84-2211, NUDOCS 8409050246 | |
| Download: ML20096C355 (3) | |
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GPU Nuclear Corporation NUCIMr Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:
August 24, 1984 5211-84-2211 Dr. Thomas E. Murley Region I, Regional Administrator U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Dr. Murley:
Three Mile Island Nu:: lear Station, Ur.it 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Notice of Violation for Inspection 84-06 Attached to this letter is the GPUN response to Appendix A of Inspection Report 50-289/84-06, " Notice of Violation." This letter is being submitted late as discussed with R. Conte, NRC.
Sincerely, f
H. D.
tkill i
Director, TMI-l HDH:CWS:vjf Enclosure cc:
R. Conte i
Sworn and Subscribed to Before me this 96.st. day of a. 3. o
, 1984.
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v a-s NOTICE OF VIOLATION As a result of the inspection conducted on February 12, 1984 to April 12,
~1984, and in 'accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the.following violation was identified:
~
10 CFR 50, Appendix B,JCriterion XV requires that "... Non-conforming items-
- shall-be: reviewed and accepted, rejected, repaired or re' orked in accordance w
with documented procedures."
Section 8.3.5 of. licensee QA Procedure No. TMI-15-03 Revision -1, states in part. that: '"the cognizant engineer will perform an evaluation of the nonconformances, proposed dispositions... For all MNCR's the appropriate-disposition category shall'be checked and the technical justification stated
. for. Repair or Use-As-Is disposition."*
~
' Section 2.4 of-the Design Control Procedure No. 2.05 for Field Change Requests and Design Verification Records (DVR) states,Lin part, that:
" Verification
~shall be recorded on the DVR form gal-468 (attachment 1). This attachment requires.that the verification package include documents to be verified, supporting documents,~ extent of verification and results of verification.
Contrary to the above, on March 9,1984, the inspector noted that the licensee was not documenting the technical justification for Use-As-Is' disposition of deviations /nonconformances identified in Field Change Request C-005021.
e
- Note: The original notice of violation reference "section 4.5.1 of licensee
. procedure No. EMP-015". This reference was later revised as above through discussions with the resident inspector.
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RESPONSE TO NOTICE OF VIOLATION I.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED A GPUN evaluation of the design verification documentation process was performed.
It indicated that the technical adequacy of the disposition in question was not adversely impacted by the apparent lack of justification for that_ disposition. Typically, additional calculations or analyses are not required to justify the impact of minor variances from the original. design which are determined to be within the original design bases.
'For design verification of Field Change Request No. 005021 (FCR-005021) the-Piping Department at Gilbert Associates Inc. (GAI) had utilized a departmental form in place of Design Verification Record (DVR) form GAI-468. This was corrected through direction from GPUN to the GAI
. Project Management Staff.
.This.was;found to be an isolated occurrence, limited to the GAI Piping Department.
II. CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION A GPUN directed joint GPUN/GAI/QA audit was performed on March 14, 1984 to determine if other discrepancies existed. Based on review of various
- design verification records, the audit concluded that sufficient documented analyses / calculations were in the design files, to justify-approvals of design changes. The documentation levels were found to be adequate ~in accordance with the written GPUN and GAI procedures.
Additional calculations / analyses required for design verification of changes from the original design are. performed, if required.
GAI Project Management also provided corrective measures to ensure that
.all GAI departments supporting TMI-1 were using the required forms as discussed above.
We believe these actions provide acceptable and auditable verification documentation for the design changes for all Field Change Requests.
'III.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved for the adequacy of disposition justification for FCR-005021 as identified in this response.
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