ML20204F700
| ML20204F700 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/13/1983 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20204F687 | List: |
| References | |
| 5211-83-114, NUDOCS 8305020232 | |
| Download: ML20204F700 (3) | |
Text
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GPU Nuclear Corporation
& U iuclear mis =Ss48o 8
Middletown, Pennsylvania 17057 717 944-7621 TELEX 84-2386 Writer"s Direct Dial Number:
April 13, 1983 5211-83-114 Regional Administrator Region I U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Sir:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Response to Inspection Report 50-289/83-05 This letter is submitted in response to the subject Inspection Report, Notice of Violation, dated March 14, 1983. Attachment 1 contains our reply and specific corrective actions in accordance with the provisions of 10 CFR 2.201.
Sincerely,
)
H'.
D.
~ ill Director, TMI-l HDH: CJS:vj f Enclosures cc:
R. Conte Sworn and Subscribed to before me this 13th day of April 1983.
[
Notary Public JUUA L PARK, !btsry Pdlic M!daMur, Dauphin Ccur:ty, Pa.
t/y Commission Expires Nov.3,19M 8305020232 830426 PDR ADOCK 05000289 0
PDR GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
ATTACHMENT I NOTICE OF VIOLATION As a result of the inspection conducted on January 31, 1983, through February 28, 1983, and in accordance with NRC Enforcement Policy (10 CFR Part 2, Appendix C), 47 FR 9987 (March 9, 1982), the following violation was identified.
Facility Operating License No. DPR-50, paragraph 2.c.6(3), Amendment No. 71 dated August 3, 1981, requires in part that the licensee shall propose alternatives to inservice tests with appropriate justification by listed resolution dates for each of the items listed in Table 2.2 (of the Inservice Testing Program Safety Evaluation Report by the Office of Nuclear Reactor Regulation, attached to License Amendment No. 71). Table 2.2 lists various safety related equipment and associated inservice pump / valve tests with required resolution dates between December 31, 1981 and September 30, 1982.
Contrary to the above from December 31, 1981 t o Feb rua ry 28, 1983, justification for alternative inservice tests for the safety related equipment listed (by reference) in the license condition was not proposed to the NRC.
This is a Severity Level V Violation (Supplement 1).
RESPONSE
1)
Background Information As stated in the above Notice of Violation GPUN did not fully comply with the schedule specified in License Amendment No. 71.
There are, however, several mitigating factors which should be noted.
A) Due to the essential nature of the extensive Steam Generator (OTSG) tube repair program, several key individuals were diverted from the activities necessary to prepare the responses to the testing
[
issues as scheduled in Table 2.2.
B) The date for proposed resolution for Item A.2 of Table 2.2 was 3/1/82.
Although we did not submit our proposed resolution by that date, we did subnit it by letter (5211-83-207) dated December 7, 1982.
C) The implementation dates of any final resolutions to these open items have not been severely impacted.
- 1) Valve Testing Items are not scheduled (in Table 2.2) to be implemented until the "end of cycle, first cycle after restart" i
(Cycle 6).
We, therefore, have not benefited, nor has the l
public health or safety been impacted by our delayed response (See corrective actions below).
ii) Pump Testing Item A.2. Although our response was nine (9) months late, it had already been resolved by virtue of the NRC publishing in a Federal Register Notice (Vol. 46, No. 251) their acceptance of 1980 edition, through winter 1980 Addenda to Section XI of the ASME B&PV Code, which permits quarterly testing of these particular pumps.
iii) Pump Testing Item A.I.
We have requested that the flow test implementation date by Cycle 6 like the valve testing items above. This is to permit installation of flow measuring devices.
D) Due to our existing extended shutdown at TMI-1, the tests specified in Table 2.2 are not currently required to be done.
- 2) Corrective Steps Which Have Been Taken and Results Achieved Our proposed resolutions to each specific item of Table 2.2 were addressed by GPUN letter (5211-83-060) dated March 28, 1983.
- 3) Corrective Steps Which Will Be Taken to Avoid Further Violations Formal action items had been issued to track completion of the items.
However, date extensions were granted based on failure on our part to recognize that the specified duties were a formal license condition.
(The requirement to propose resolution of the items appeared in both the cover letter for Amendment 71 and as license conditions.)
In addition, it was known that no testing is required during our current shutdown.
This is considered to be an isolated error and no further corrective action is considered necessary.
- 4) Date When Full Compliance Will Be Achieved Full compliance was achieved March 28, 1983.