ML20098E688
| ML20098E688 | |
| 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) |
| Shared Package | |
| ML20098E679 | List: |
| References | |
| 5211-84-2211, NUDOCS 8410010286 | |
| Download: ML20098E688 (3) | |
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3 f5 Nuclear GPU Nuclear Corporation
- ,omar8o Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Olal 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 Nuclear Station, Unit 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 submitt2d late as discussed with R. Conte, NRC.
Sincerely,
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H. D.
okill Director, THI-1 HDH:CWS:vjf Enclosure cc:
R. Conte Sworn and Subscribed to Before me this 1>La. day of m 3.o
, 1984.
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.a _orns county 8410010286 840925 My COMMIS$10N IIPIRES JUNE 17.1985 PDR ADOCK 05000
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GPU Nuclear Corporat!on is a subsidiary of the General Public Utilities Corporation
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NOT CE OF' VIOLATION m
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' 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' follow:ng1 violation was identified:
1) 10 CFR 50, Appendix B,. Criterion XV requires that "... Non-conforming items shall'be^ reviewed and acc'epted, rejected.: repaired or reworked in accordance 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, in 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.
2 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.
1
- Note: The original notice of violation reference "section 4.5.1 of licensee procedure No. EMP-015".
This reference was later revised as above p
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.
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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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