ML20154Q422
| ML20154Q422 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/14/1986 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 5211-86-2046, NUDOCS 8603210160 | |
| Download: ML20154Q422 (3) | |
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o GPU Nuclear Corporation Nuclear
=,omeer8o s
Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:
March 14, 1986 5211-86-2046 Dr. Thomas E. Murley Region I, Regional Administrator U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19405
Dear Dr. Murley:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License Nos. DPR-50 Docket Nos. 50-289 Response to Notice of Violation and Comment on Inspection Report 85-30 Attached is the GPUN response to Appendix A of Inspection Report No.
50-289/85-30 ~' Notice of Violation."
GPUN takes exception to a statement on page 15 of IR 85-30 The NRC statement that "the licensee wanted to restart the plant without a complete understanding of the effects of the Furmanite mterial in the steam generator" is untrue. The effects of the use of Furmanite in the plant were well understood by Plant management because of past experience and existing documentation.
No chemistry concerns were identified nor was there a concern on any possible secondary system damage as a result of a small amount of Furmanite entering the secondary system.
A 10 CFR 50.59 written evaluation was prepared at the request of the NRC subsequent to the plant startup so there would be sufficient written documentation.
Sincerely, G603210160 060314 PDR ADOCK 05000209 G
PDR U*
'Ill Director, TMI-l HDH/SM0/spb:0529A Attachment Sworn and subscribed to before rne this ///A cc:
W. Kane day of 7MdML 1986.
R. Conte 5HuoN P. ERcwN. harm runic E100l! TOWN CORO. DAUPHIN COUNTY
[ilic uf COMEissicN Inuits JUNE 12, liH ggg y gy Men 1ber, Pennsybania Asscelation of Notarly Notar Put GPU Nuclear Corporation is a subsidiary of the General Pub c utilities Corporation
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NOTICE OF VIOLATIOF' During an NRC inspection conducted between December 13, 1985 and January 10, 1986, a violation of NRC requirements was identified.
In accordance with the 4
" General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (1985), the violation is set forth below:
Technical Specification 4.18.7.2.c requires that fire doors shall be verified to be functional by a visual inspection at least daily for doors neither locked nor supervised to l
verify that they are in a closed position, i
Contrary to the above, during December 16-19,1985, fire door D-108 (not locked or supervised) was not visually verified to be functional in a closed position and was found j
to be ajar.
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RESPONSE TO HOTICE OF VIOLATION 1
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Corrective Steps Taken and Results Achieved I
On December 19, 1985, immediately following notification that fire door j
D-108 was ajar, the door was closed by an Operations representative.
j Security personnel, in making their twice-per-shif t rounds, pass through i
door D-108 and are under instruction to ensure all vital area doors,
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including fire doors, are closed when they pass through them.
l Surveillance Procedure SP 1303-12.20, Revision 4, effective December 20, 1985, contained the required controls for ::urveillance of fire door 1
D-108. The issuance of SP 1303-12.20, Rev. 4 and the performance of the l'
compliance with Technical Specification 4.18.7.2.C.
surveillance on December 20, 1985, resulted in the re-establishment of II.
Corrective Steps To Be Taken To Avoid Further Violations 1
j The cause of this violation was the lack of identification of related l
procedure changes. SP 1303-12.22, Rev. 4 (implemented Decerrber 16, j
1985) deleted fire door D-108 from surveillance.
SP 1303-12.20, Rev. 4 (implemented December 20,1985) added the surveillance of fire door
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D-108. Although the Procedure Change Requests to effect these changes were prepared and entered into the review and approval process j
simultaneously, the changes were not implemented simultaneously, Issuance of SP 1303-l?.22, Rev. 4 prior to SP 1303-12.20, Rev. 4 i
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resulted in the deletion of the required surveillance, thereby resulting in a non-compliance with Technical Specification 4.18.7.2.C.
A memorandum was issued on March 3,1986 by the Review Program Coordinator, TMI-l to TMI-1 management to emphasize the need for procedure preparers / owners / responsible offices to clearly identify the need to process related procedure changes simultaneously. The memorandum encourages preparers / owners / responsible offices to identify I
this need in writing on the respective Procedure Change Request (PCR) forms. Following receipt of notification of the need to process related i
procedure changes together, the TMI-l Procedure Coordinator will log and track review / approval of the documents to ensure simultaneous implementation.
No further corrective action is planned.
III. Date of Full Compliance i
Full compliance with Technical Specification 4.18.7.2.C was achieved l
December 20, 1985 upon issuance and performance of Surveillance Procedure 1303-12.20, Rev. 4.
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