ML20196C938
| ML20196C938 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/21/1988 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| C311-88-2161, NUDOCS 8812080143 | |
| Download: ML20196C938 (5) | |
Text
,.
s GPU Nuclear Corporation gggf Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direc.t Dial Nuniber.
November 21, 1988 C311 2161 Mr. William T. Russell Region I, Regional Administrator US Huclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406
Dear Mr. Russell:
Three Mile Island Huclear Station, Unit 1 (THI-1)
Operating License No. DPR-50 Docket No. 50-289 Response to Notice of Violation in Inspection Report 88-17 Enclosed is GPlJN's response to the Hotice of Violation in Inspectiori Report 88-17. This violation response is being submitted two days late as discussed with R. Conte, Senior Resident Inspector.
Sincerely, Hukill Vice President A Director, THI-1 HDH/SM0/spb:1303A cc:
R. Conte R. Hernan Docurent Control Desk Sworn and subscribed to before me this J7tWday of 7)nu n fr o, 1988
.dt_a(r77 b 16 oW sonstSEg
/
Notary Public sv5CN P BCAS.f40W P' M u 0%ETO A'i Boro. Opoi col *4W l
uY C%icsci EW;E$.'AE 12.139 l
pn s. Sn t/.wa htm ct ?k%w 8S120801 6 1 1
PDR ADOCK 05000289 Q
FDC
&D\\
r m
o o
B.
The TMI-l Technical Specifications, paragraph 6.8.2 states in part:
"... substantive changes [to procedures] shall be reviewed and approved... ", and paragraph 6.8.3.c states in part: "Tenporary changes to procedures..
may be made provided the change is documented, reviewed and approved... within 14 days of irplenentation."
Contrary to the above, during work completed prior to July 15,1988 on the Reactor Coolant pumps, a substantive terporary change was made to Procedure 1410-1.4, which was not reviewed and approved within 14 days of impl ementa tion. The incremental torque value in Step 6.1.12.? of the procedure had been changed in the field by lining out one torque value ind inserting another.
This change was not approved prior to the initiation of work nor was the review and approval to this change initiated until August 11, 1988, approximately one renth after the change was made.
Further, Procedure 1407-1, "Corrective Maintenance" does not conform to the requirerents of T.S. 6.8.2 and 6.8.3, in that it permits workers to make temporary changes and to irplement them without any prior authorization or subsequent review within the 14 day period.
This is a Severity level IV violation (Supplement I).
Pesponse (1) Corrective Actions Taken Procedure 1401-1.4 was revised to correct the toroue value effective Septerber 20, 1988.
(?) Corrective Actions Taken to Prevent Pecurrence Several organizations failed to recognize the need for a terporary change to 1401-1.a prior to proceeding with the work.
Adequate guidance exists on the proper rethod of changing procedures.
Personnel will be reninded of requirements through a required reading assignnent consisting of:
(1) this violation response, (2) Administrative Procedure 1001G, "Procedure Utilization, (3) Administrative Procedure 1001 A, "Procedure Peview and Approval - Sections 4.4 and 4.5."
All PCAF Construction Management personnel, TMI-l UESC-Catalytic supervisory personnel, and Plant Materiel personnel will be required to complete the required reading assignment.
(3) Date of Full Corpliance Personnel will corplete the reading assignrent by January 31, 1089.
i
We disagree with the assertion that Procedure 1407-1 permits workers to make temporary changes to procedures without prior authorization or subsequent review within 14 days.
Procedure 1407-1 does not specifically address how changes to standing maintenance procedures, such as Procedure la01-1.4, are to be nade.
Such instructions are provided in i
procedure 1001 A "Procedure Review and Approval," which specifies the l
methods of changing procedures in compliance with Technical Specification 6.8.2 and 6.8.3.
Procedure 1001 A is referenced in Procedure 1407-1 The manner in which the torque value in Procedure 1401-1.4 was changed was not in compliance with Procedure 1001 A.
This was a personnel error in that the individuals involved did not comply with the requirements of 1001A.
i 1
(2) Corrective Actions Taken to Prevent Recurrence We do not agree that Procedure 1410-P-7 was inadequate because it did not incorporate the vendor requirement to inspect the makeup pump seals for a specified flatness, Procedure 1410-P-7 "Assembly and Disassembly of Centrifugal Pumps' is a generic procedure for any centrifugal purp.
Procedure 1410-P-7 was adequate in that it states that assembly should be in accordance with manufacturer's instructions.
Specific vendor information should be incorporated into the appropriate technical manual.
During the replacement of the makeup pump seals, the fatlure to use the nost recent vendor information was due to the information not being forwarded to the Vendor Document Control organization.
This organization would have then disseminated the information to the appropriate plant groups involved in the job.
To prevent this from r? curring. GPUN will review the current program to ensure vendor information for previously and newly procured items is directed to the Vendor Docurent Control organization and other appropriate organizations.
(3) Date of Full Compliance GPUN will review and, if necessary, revise the program discuss?d above by June 30, 1939, i
,o Notice of Violation (A)
A.
The Three Mile Isianti Nuclear Generating Station, Unit 1 (TMI-1) Technical Specifications, paragraph 6.8.1 states in part:
"Written procedures shall be established, implemented and maintained."
Contrary to the above, on August 19, 1988 the following two procedures were not adequately established.
(1) Procedure 1107-3, Diesel Generator, Revision 33 did not include the Emergency Diesel Generators Turbochargers Jacket Cooling 1 inch globe valves in the valve lineup list.
These valves serve a safety function by providing a flow path for the turbocharger jacket coolant.
(2) Procedure 1410-P-7 did not incorporate requirements to inspect the reactor coolant system makeup pump seals for specified flatness and rework as necessary prior to installation.
This technical information was made available from the vendor of the replacemnt seals on Purchase Order TP-05-9051 Because the seals were installed without a flatness check, they failed a subsequent water leakage test.
This is a Severity Level IV violation (Supplement I).
Response
Items (1) and (2) will be addressed separately.
Item (1)
(1) Corrective Actions Taken A Procedure Change Request has been submitted to revise Procedure 1107-3 to include the globe valves on the valve lineup list.
(2) Corrective Actions Taken to Prevent Recurrence No further action is necessary beyond revision of Procedure 1107-3.
(3) Date of Full Compliance Procedure 1107-3 will be revised by December 31, 1988 Item 2 l
(1) Corrective Actions Taken The makeup pump seals were reworked and the water leakage was acceptable for operation prior to plant heatup.
I