ML20206U427
| ML20206U427 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/29/1986 |
| From: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| Shared Package | |
| ML20206U430 | List: |
| References | |
| EA-86-146, NUDOCS 8610070496 | |
| Download: ML20206U427 (3) | |
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u Docket No. 50-320 License No. DPR-73 EA 86-146 General Public Utilities Nuclear Corporation ATTN: Mr. P. R. Clark, President 100 Interpace Parkway Parsippany, New Jersey 07054 Gentlemen:
Subject:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES (INVESTIGATION REPORT NOS. H-83-002 and I-84-029)
This refers to investigations conducted March 25 - August 10, 1983 and November 1,1984 to September 5,1985 by the NRC's Office of Investigations (01).
In February 1983, the NRC received allegations involving weaknesses in procedural and management control of activities conducted at Three Mile Island, Unit 2 (TMI-2) involving the refurbishment work associated with the Reactor Building Polar Crane. After an initial 01 investigation of the allegations, the Office of Inspection and Enforcement (IE) issued a Notice of Violation (NOV) on February 3,1984. You responded to this NOV on February 28, 1984 and by letter dated April 18, 1984 from Richard DeYour.g to P. R. Clark, the action was resolved.
However, by letters dated October 5 and October 8,1984, GPU Nuclear notified
- b staff that additirral rrodifications were made to the Peactor Building Polar Crane without prcper engir.eering review and docua.entation.
Trese
'c i r. ca ti on s ir.volved the aedition of a hand release techanism which airectly af fected the ability of the main hoist brakes to properly function. OI was subsequently asked to investigate this issue as well. A Report of Investigation was issued on Septer.ter 23, 1985 and the report was made public shortly therea^er. We have consicered your submittals on January 15 and February i8,1986 of reports prepared by r,ennedy P. Richardson and Edwin Stier regarding the results of the investigation.
The information provided in these reports was considered in ceveloping this proposed enforcement action.
Based on our review of the original procedural violations and of the hand release raechanism incident, the addition of the hand release mechanism appears to be dnother more serious example of the original violations in which modifications were made to the Reactor Building Polar Crane without proper engineering review and documentation.
This violation directly affected the ability of the main hoist brakes to properly function.
In addition, GPU Nuclear and Bechtel Northern Corporation (BNoC) personnel were aware of the requirements to comply nith GPU Nuclear's approved procedures and the fact that BNoC was not complying with CERTIFIED MAIL RETURN RECEIPT REQUESTED 8610070496 860929 h
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d GPU Nuclear Corporation tnem with regard to refurbishment of the polar crane.
JSerefore, the violation was apparently willful.
In accordance with one General Statement of Policy and Procedure for NRC Enforcement Actions,10 CFR Part 2, Appendix C (1986), the viole. tion has been categorized as a Severity Level III violation.
To emphasize the need for you to properly control the activities of your contractors performing modifications, I have been authorized, after consultation with the Consnission, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Forty Thousand Dollars ($40,000) for the violation described in the enclosed Notice. The base civil penalty for a Severity Level III violation at the time it occurred was $40,000. We examined the escalation and mitigation factors allowed by the Enforcement Policy and none were considered appropriate.
In addition to the above violation, we noted that in response to questions in a July 18, 1983 letter from the NRC staff regarding any modifications to the crane that were not "in-like kind," the Site Director, TMI-2, stated in a letter dated August 16,1983, "The polar crane's two main hoist brakes were replaced in kind." Page 8 of art attachment to that letter identified a list of items as " replacement-in-kind" parts on tne polar crane, including the main hoist brakes. The statements were not accurate because the main hoist brakes were not replaced "in-kind." The new brakes included a hand release mechanism not on the original brakes which added an additional function to the brakes (ability to lower a load in case of a power failure) and was identified by the vendor as complicating maintenance (Westinghouse Leaflet No. 3710-2).
If the staff had known that the brakes had not been replaced "in-kind" it would have requested additional information to ensure that the modification had been performed in accordance with procedures and had received appropriate design, engineering, and quality assurance reviews.
On Septelter 26, 1983, the NRC Deputy Frograra Cirector, TGO, addresseo further femal questicos to the licensee specifically requiring, among other things, that "you should review the modifications for tne polar crane and certify to NRC that modifications involving unlike kind components have been evaluated and reviewed in accordance with applicable administrative procedures."
GPbh's responses, dated October 11 and 25, 1983, failed to inform the NRC that the main hoist brakes of the polar crane had not been replaced in-kina.
OI stateo in its report (I-84-029) that "No evidence was oeveloped to indicate that Licensee Management knowingly intended to deceive the NRC when, in written and verbal communications, they described the main hoist brakes as replaced
'in-kind'."
We have concluded that at the time he signed the letter, the TMI-2 Site Director was not aware that the brakes had not been replaced in-kind.
Therefore, we do not believe that the statements were knowingly or intentionally made and have decided not to cite for a material false statement. However, in view of the intense attention that was paid to this issue at the time the submittal was made, the repeated questioning by the NRC on whether there were any additional unlike-kind replacements, and the ability to identify the addition of the hand release mechanism from drawings and discussions with the many personnel on-site who knew of its existence, we believe additional
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y GPU Nuclear Corporation attention should have been devoted to ensuring the accuracy of these submittals and expect that future submittals will be complete and accurate in all significant respects.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence.
In responding to the Notice you may incorporate by reference previous submittals as appropriate. After reviewing your response to this Notice, including your proposed corrective actions, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regclations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Sincerely, T/W s T.nTaylo,7 Director a
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,,0ffice of Inspection and Enforcement
Enclosure:
<'repused Im m,.ian of Civil Peralties