ML20129B347

Forwards Insp Rept 50-289/96-05 on 960803 & Nov.Violations Re Failure to Establish Proper Design Control Measure,When Determining Valve Factors Being Cited as Violation of NRC Requirements

ML20129B347
Person / Time
Site:	Three Mile Island
Issue date:	09/13/1996
From:	Eselgroth P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	James Knubel GENERAL PUBLIC UTILITIES CORP.
Shared Package
ML20129B351	List: ML20129B347 ML20129B360 ML20129B376
References
GL-89-10, NUDOCS 9609230011
Download: ML20129B347 (3)

See also: IR 05000289/1996005

Text

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Septamber 13,1996

Mr. James Knubel

Vice President and Director, TMI

GPU Nuclear Corporation

Three Mile Island Nuclear Station

Post Office Box 480

Middletown, PA 17057-0191

SUBJECT: NRC INTEGRATED INSPECTION REPORT N0. 50-289/96-05 AND NOTICES

OF VIOLATION

Dear Mr. Knubel:

On August 3,1996, the NRC completed an inspection at your Three Mile Island 1 reactor

facility. The enclosed report presents the results of that inspection.

A continued trend related to senior reactor operators' evaluation of degraded Technical

Specification equipment operability determinations and documentation warrants additional

management attention. The most recent example was related to the undetected reduction

of auxiliary and fuel handling building ventilation flow below the Technical Specification

minimum value. The operator's excellent response to the fuse clip failure for the station

blackout diesel was an example of positive performance related to the application of good

self checking techniques.

Your Generic Letter (GL) 89-10 Motor-Operated Valve Program was originally scheduled for

completion in June 1994. The completion date was later revised to the end of the 11R

refuel outatie, October 1995, following several meetings with the NRC. Despite these

interactioni, the program has remained substantially incomplete 18 months later, with

several fundamental weaknesses, ineffective oversight, and an apparent lack of ownership.

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The technical inconsistencies were reflected by not just informality and poor

documentation, but also weak design control and unfounded engineering assumptions. For

example, valve factors - a critical design input parameter - were inadequately justified for

over half of the untested valve groups. Basic assumptions related to diagnostic uncertainty

and load-sensitive behavior were miscalculated or improperly estimated; and, for several

valve families with marginal capability, such as the pressurizer power operated relief valve

block valves and several secondary side isolation valves, the design-basis assumptions

were unclear and inconsistent with respect to the current TMl licensing basis. The NRC

- was unable to close the TMI MOV program, margins for certain valves remain relatively

small, and design-basis capability has not been adequately verified by GPUN. [f

Based on the results of this inspection, certain of your activities appeared to be in violation

of NRC requirements, as specified in the enclosed Notice of Violation. The failure to I/

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230013 "

9609230011 960913

PDR ADOCK 05000289-

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Mr. James Knubel 2 l

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establish proper design control measure, when determining valve factors, is being cited as

! a violation of NRC requirements. i

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You are required to respond to this letter and should follow the instructions specified in the

j enclosed Notice when preparing your response. In your response, you should document  ;

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j the specific actions taken and any additional actions you plan to prevent recurrence. Your

! response may reference or include previous docketed correspondence, if the

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correspondence adequately addresses the required response. After reviewing your

response to this Notice, including your proposed corrective actions and the results of

, future inspections, the NRC will dctermine whether further NRC enforcement action is

necessary to ensure compliance with NRC regulatory requirements.

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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter  ;

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and its enclosures will be placed in the NRC Public Document Room. To the extent

possible, your response should not include any personal privacy, proprietary, or safeguards

l information so that it can be placed in the PDR without redaction.

! The responses directed by this letter and the enclosed Notice are not subject to the

clearance procedures of the Office of Management and Budget as required by the

l Paperwork Reduction Act of 1980, Public Law No. 96.511. ,

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l We appreciate your cooperation. j

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Sincerely, l

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ORIGINAL SIGNED BY.

Peter W. Eselgroth, Chief

Projects Branch No. 7

Division of Reactor Projects

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Docket No.: 50-289  ;

License No.: DPR-50  ;

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. Enclosures-

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l 1. Notices of Violation.

2. NRC Inspection Report No. 50-289/96-05 i

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3. NRC/GPU Nuclear Management Meeting Presentation Slides i

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cc w/ encl:

E. L. Blake, Shaw, Pittman, Potts and Trowbridge (Legal Counsel for GPUN) l

Commonwealth of Pennsylvania l

J. C. Fornicola, Director, Licensing and Regulatory Affairs i

M. J. Ross, Director, Operations and Maintenance l

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. TMI-Alert (TMIA)

J. S. Wetmore, Manager, TMl Regulatory Affairs ]

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Mr. James Knubel 3

Distribution w/ encl:

Region I Docket Room (with concurrences)

T. Kenny, DRS

P. Eselgroth, DRP

D. Haverkamp, DRP

NRC Resident inspector -

Nuclear Safety Information Center (NSIC)

PUBLIC

D. Screnci, PAO

Distribution w/enci (VIA E-MAIL):

W. Dean, OEDO

J. Norris, PD l-4, NRR

P. McKee, PD l-4, NRR

inspection Program Branch, NRR (IPAS)

M. Davis, NRR (MJD1) (For FSAR info only)

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DOCUMENT NAME: G:\ BRANCH 7\TMi\TMl9605.lNS

To receive a copy of this document, indicate in the box: "C" = Copy without

attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy

OFFICE .

Rl/DRP gp Rl/DRP3 pr g / /

NAME kHANSEL@ ESELdgpH,

DATEV 09/05/96' 09/B9E

OFFICIAL RECORD COPY