ML20204J023

Notice of Violation from Insp on 880808-19.Violations Noted: Procedures 1107-3 & 1410-P-7 Not Adequately Established & Temporary Change Made to Procedure 1410-1.4 Not Reviewed & Approved within 14 Days of Implementation

ML20204J023
Person / Time
Site:	Three Mile Island
Issue date:	10/17/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20204H998	List: IR 05000289/1988017 ML20204H995 ML20204J023
References
50-289-88-17, NUDOCS 8810240520
Download: ML20204J023 (2)

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APPENDIX A NOTICE OF VIOLATION GPU' Nuclear Corporation Docket No. 50-289 Thr~ Mile Island Nuclear Generating Station Unit 1 License No. DPR-50 As a result of the inspection conducted on August 8-19, 1988, and in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement Policy) (1988),

the following two violations were identified:

A. The Three Mile Island 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, or. 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 Turbnchargers 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 jiaket 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 replacement seals on Purchase Order TP-05-9051. Because the seals were installed without a flatness check, they failed a subsequent water leaktge test.

This is a Severity Level IV violation (Supplement I).

B. Yhe THI-1 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: "Temporary changes to procedures . . may be made provided the change is documented, revir.wed and approved . . . within 14 days of implementa*. ion."

Contrary to the above, during work completed p'ior to July 15, 1988 on the Reactor Coolant pumps, a substantive temporary cha1ge was m Je to Procedure 1410-1.4, which was not reviewed and approved within 14 days of implementation. The incremental torque value 1. ,tep 6.1.12.2 of the procedure had been changed in the field by lining out one torque value and inserting another. This change was not approved prior to the initiation OFFICIAL RECORD COPY IR TM1 89 0003.0.0 10/17/88 8910240520 891017 PDR ADOCK 050002:!.9 0 PDC L

, , , , . g Appendix A 2 of work nor was the review and approval to this change initiated until August 11, 1988, approximately one month after the change was made.

Further, procedure 1407-1, "Corrective Maintenance" does not conform to i the requirements of T.S 6.8.2 and 6.8.3, in that it permits workers to I make temporary changes and to implement them without any prior authorization or subsequent review within the 14 day period.

i This is a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, GPU Nuclear Corporation is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved, (2) corrective steps which will be taken to avoid further violation; and (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending this response time.

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s OFFICIAL RECORD COPY IR TM1 88 0003.1.0 10/17/88