ML20204H560
| ML20204H560 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/01/1984 |
| From: | Standerfer F GENERAL PUBLIC UTILITIES CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 4410-84-L-0191, 4410-84-L-191, ID-0109A, ID-109A, NUDOCS 8411120318 | |
| Download: ML20204H560 (5) | |
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Middletown Pennsylvania 17057-0191 717 944 7621 TELEX 84-2386 Writer's Direct Dial Number:
(717) 948-8461 4410-84-L-0191 Document ID 0109A November 1, 1984 Office of Inspection and Enforcement Attn: Dr. T. E. Murley Regional Administrator US Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Dr. Murley:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Inspection Report 84-08 The subject Inspection Report dated October 2, 1984, identified four (4) apparent items of non-compliance. The attachment to this letter provides the GPU Nuclear response to each citation.
If you have any questions concerning this information, please call Mr. J. J. Byrne of my staff.
Sincerely, U
. R. Standerf Vice President Director, TMI-2 FRS/RDW/jep Attachment cc: Program Director - TMI Program Office, Dr. B. J. Snyder Deputy Program Director - TMI Program Office, Dr. W. D. Travers 841112031e e41gog PDR ADOCK 05000320 O
PDR GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation 9
N 6 M 0$ 91 01 STATE!ENT OF VIOLATION 10 CFR 50.59(a)(1) allows-licensees to make changes to the facility as described in the Safety Analysis Report without prior Commission approval, provided the changes do not involve an Unreviewed Safety Question.
10 CFR 50.59(b) further requires that licensees maintain records of chtiges made pursuant to 10 CFR 50.59, including written safety evaluations providing the bases for the determination that the changes do not involve Unreviewed Safety Questions.
Contrary to the above, the licensee has continuously made temporary modifications pursuant to Procedure 4000-ADM-3020.08, Revision 0,
" Configuration Control: Safety Evaluation Bypass, Electrical Jumper, Lifted Lead, and Temporary Modifications" without determining whether the modifications were changes to the facility as described in the Safety Analysis Report or involved Unreviewed Safety Questions. These temporary modifications involve those systems and components which are not listed on the Quality Classification List (QCL) that may have an impact on safety. Furthermore, records maintained pursuant to 4000-ADM-3020.08 of some changes to systems or components listed on the QCL and evaluated per 10 CFR 50.59 lacked written safety evaluations supporting the determination that the changes did not involve Unreviewed Safety Questions.
This is a Severity Level IV Violation (Supplement I).
GPU NUCLEAR RESPONSE Revision 1 to Procedure 4000-ADM-3020.08, which became effective June 6, 1984 requires a Unit Work Instruction (UWI)/ Work Request Authorization (WRA)r or an approved procedure for the installation of any jumper, lifted lead, or temporary mechanical modification. A preliminary evaluation, including 10 CFR 50.59 review, is required for all UWI's/WRA's and procedures in accordance with GPU Nuclear Procedure 4000-ADM-1218.02, "TMI-2 Document Evaluatico, Review, and Approval". Therefore, procedures require all temporary rnodifications to undergo 10 CFR 50.59 evaluation prior to implementation. However, Procedure 4000-ADM-3020.08, as currently written, 1 glies that a safety evaluation is only required for Important to Safety (ITS) applications. A Procedure Change Request (PCR) has been initiated which will delete this ambiguity and establish unambiguously that a safety evaluation is required for all temporary modifications. This procedure change is expected to be approved and implemented by December 31, 1984.
With respect to the concern of inadequate 10 CFR 50.59 evaluations, GPU Nuclear conducted training from August through October of this year for Document Preparers and Responsible Technical Reviewers (RTR's) on the definition, application, and proper method of completing a 10 CFR 50.59 evaluation. Incorporated into this training were the findings of the Performance Appraisal; Team.
NI6 M 0$ 191 0
STATEMENT OF VIOLATION The GPU Nuclear Recovery Quality Assurance Plan for TMI-2, Revision 2, January 19, 1983, Section 6.8.1.2, requires procedures for identification of the operating status of systems, components, controls, or support equipment in order to prevent inadvertent or unauthorized cperation. The procedures shall require control measures such as locking or tagging and shall require independent verification where appropriate to ensure that necessary measures have been implemented correctly.
Contrary to the above, Section 6.8.1.2 of the GPU Nuclear Recovery Quality Assurance Plan was not implemented in the following cases:
Procedure 4000-ADM-3020.04, " Switching and Tagging Safety", Revision 0, prescribed control measures for equipment tagging, but did not require independent verification of tagging in all appropriate cases.
Procedure 4000-ADM-3020.05, Tontrolled Key Locker", Revision 0, prescribed the control measures for locking valves but did not require independent verification of valve position or installation of locking devices.
This is a Severity Level IV Violation (Supplement I).
GPU NUCLEAR RESPONSE GPU Nuclear will require independent verification for the following evolutions: manipulation of components listed in the locked valve log, returning Technical Specification equipment to service, returning containment integrity valves to service following switching and tagging operations, and operation of deboration control components. Accordingly, in order to implement these requirements, PCR's have been initiated for procedures 4000-ADM-3020.05, " Controlled Key Locker", 4000-ADM-3020.04,
" Switching and Tagging Safety", 4000-ADM-3061.01, " Recovery Operations Plan Surveillance Test Program", and 4210-ADM-3020.01, " Conduct of Plant Operations". GPU Nuclear anticipates that these revised procedures will be in effect by November 30, 1984, at which time full compliance will be achieved. Following implementation, the procedures will be reviewed by the appropriate plant personnel.
STATEENT OF VIOLATION Section 6.1.2 and Appendix C of the GPU Nuclear Recovery Quality Assurance Plan requires the implementation of the requirements of Regulatory Guide 1.33, Revision 2, 1978, and ANSI N18.7-1976, in procedures governing station activities. Section 5.3.5 of ANSI N18.7-1976, as endorsed by Regulatory Guide 1.33, requires that where vendor manuals or drawings provide adequate instructions to assure the required quality of work, the applicable sections of the manual or drawings shall be referenced in the procedure, or may constitute adequate procedures in themselves. Such procedures shall receive the same level _of review and approval as operating procedures.
s, V.
M D 0191 Contrary to the above, Unit Work Instruction 4220-3680-84-D-55, completed 3_
January 19, 1984, authorized the repair or replacement of the FS-P-1 battery or battery charger using procedure 1420-Y-13, " Troubleshoot and Repair of Control or Indication Circuits,' Revision 2.
Procedure 1420-Y-13 directed the
' worker to "obtain any applicable vendor's manuals". The specific manuals and/or specific sections of'the manuals were not referenced nor were the manuals reviewed and approved.
This is a. Severity Level V Violation (Supplement I,.
GPU NUCLEAR RESPONSE TMI-2's Maintenance Department is currently developing a Standing Order which will provide guidance cmcerning prerequisites referencing vendor manuals:in procedures. This Standing Order will require, in those cases where vendor manuals are utilized to control or assure the required quality of the work being performed, that the specific vendor manual (s) or applicable portions of the manual (s) will be referenced in the procedure controlling the work. Since these procedures are required to receive the same level of review and approval as an operating procedure (i.e., review by the Cognizant Engineer, Responsible Technical Reviewer, Safety Review Group, if applicable, and Site Operations Director), the referenced vendor technical literature will receive the same review. The above requirement does not. apply to evolutions where the vendor manual is
~ utilized solely for reference purposes.
-This. Standing Order will be reviewed and discussed with appropriate document preparers and RTR's as part of their continuing training.
Additionally, TMI-2 Procedure 4220-ADM-3052.01, "TMI-2 Plant Maintenance Control of Tech Manuals", has been developed. This procedure is currently under review and will establish the methodology by which Plant Maintenance will control and maintain vendor manuals.
The above corrective actions are anticipated to be implemented by December 31, 1984, at which time full compliance will have been achieved.
STATEENT OF VIOLATION
-Technical Specification 6.8.1 requires that the procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, be implemented. Appendix A of Regulatory Guide 1.33, Revision 2, 1978, recommends procedures for control of measuring and test equipment. Procedure 4000-ADM-3061.02, " Control of Measuring and Test Equipment", Revision 0, requires that when a piece of measuring and test equipment is found to be out of calibration that the Cognizant Engineer generate a Material Non-Conformance Report (MNCR) and provide corrective action. It further~ requires that the corrective action include a documented evaluation to determine if any retesting of systems or components is required as a result of the test
. equipment being out-of-calibration.
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Contrary to the above, MNCR's were not issued when measuring and test equipment was found to be out-of-calloration. Further, components of the Radiation Monitoring System Test Rig Model TM 506, Serial No. B012043, were i
found out-of-calibration on January 25, 1984, and as of March 15, 1984, only four (4) of twenty-two (22) tests using the rig since its previous calibration i
had been evaluated to determine the need for retesting.
This is a Severity Level IV Violation (Supplement I).
GPU NUCLEAR RESPONSE The requirements for measuring and test equipment have been revised such that an MNCR is not required for each instance when a piece of measuring and test equipment is out-of-calibration. GPU Nuclear Procedure 4000-ADM-3053.01, Revision 0, (previously 4000-ADM-3061.02) dated September 4, 1984, requires the issuance of an " Instrument Out-of-Spec Data Sheet" for any nonconformance (i.e., out-of-calibraton) of measuring and test equipment. The data sheet is transmitted for review to the Cognizant Engineer. Procedure 4000-ADM-3053.01 states, "the Cognizant Engineer will generate an MNCR (if appropriate) and provide corrective action. The corrective action shall include a documented evaluation to determine if any retesting of systems or conponents is required as a result of test equipment out-of-calibration". Guidance with respect to the nonconformance of measuring the test equipment is being developed which will delineate the criteria as to when an MNCR is required.
Procedure 4000-ADM-3053.01 further states, "The Cognizant Department will maintain a system to ensure a timely response to the Cognizant Engineer and the issuance of an MNCR". To ensure compliance with the requirement, on May 3, 1984, the TMI-2 Maintenance Department issued a Standing Order which implemented the following:
A log is maintained of all the Instrument Out-of-Spec Data Sheets which are sent to the Cognizant Engineer. This log is updated on a weekly basis.
An MNCR is automatically issued for any item in the log that is outstanding (i.e., has not been reviewed by the Cognizant Engineer) within one month.
GPU Nuclear anticipates full compliance with the above violation will be achieved by December 31, 1984.
Additionally, the remaining tests using the Radiation Monitoring System Test Rig Mooel TM 506, which are specifically referenced in the item of noncompliance, have been evaluated and found to be satisfactory; no testing was required.
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