ML20210H477
| ML20210H477 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/12/1986 |
| From: | Standerfer F GENERAL PUBLIC UTILITIES CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 4410-86-L-0158, 4410-86-L-158, NUDOCS 8609260178 | |
| Download: ML20210H477 (3) | |
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GPU Nuclear Corporation NggIg{
Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057-0191 717 944-7621 TELEX 84-2386 Writer's Direct Dial Nurnber:
(717) 948-8461 4410-86-L-0158 Document ID 0089P September 12, 1986 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 86-08 Inspection Report 50-320/86-08 dated August 14, 1986, identified one (1) item of non-compliance. Attached is the GPU Nuclear response to this item.
Sincerely, 9
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G
. Standerf r Vice President / Director, TMI-2 FRS/CJD/eml Attachment cc: Director - THI-2 Cleanup Project Directorate, Dr. W. D. Travers 8609260178 860912 PDR ADOCK 05000320 G
PDR GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation Q D\\
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NRC NOTICE OF VX0LATION 10 CFR 50, Appendix B, XI Test Control, requires, in part, that, "A test program shall be established to assure that all testing required to demonstrate that... components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits..."
Contrary to the above, during the period April 26, 1981 through May 6, 1986, an In-Service Inspection Program was not established, as required, to demonstrate the operational readiness of Categories B and C valves in safety related systems.
This is a Severity Level V violation.
GPU NUCLEAR RESPONSE GPU Nuclear concurs with this violation. A formal Inservice Inspection (ISI)
Program did not exist at TMI-2 during the period of April 27, 1981 through May 6,1986 due to a failure to incorporate the NRC regulatory requirement into normal plant operations. This failure was primarily due to the lack of proper licensing supervision and guidance plus the occurrence of other high priority licensing issues following the TMI-2 accident.
A brief history concerning the licensing of the TMI-2 ISI Program is helpful in summarizing the circumstances surrounding this violation.
o Prior to the TMI-2 accident, an ISI program was in effect at TMI-2 in accordance with the requirements of the TMI-2 Technical Specifications.
o The NRC Amendment of Order of February 1980, which issued the TMI-2 Recovery Technical Specifications, deleted any requirements for ISI testing, with the exception of those specifications that required cycling of valves every ninety-two (92) days.
o On April 18, 1980, GPU Nuclear submitted a letter to the NRC requesting a relief from the requirements of 10 CFR 50.55(a) concerning ISI Programs.
GPU Nuclear proposed to test ASE Category B and C valves for safety-related inservice systems in accordance with the Recovery Technical Specifications / Recovery Operations Plan.
o The NRC responded to the above letter on April 27, 1981, granting GPU Nuclear an exemption from the requirements of ISI testing with the exception of Category B and C valves. The NRC stated that requests for relief from ISI testing of these valves would have to be submitted on an individual valve basis and that valves in safety-related systems should be exercised at least once per 92 days, o
On April 9,1984, GPU Nuclear requested relief from the ISI testing requirements for various Category B and C valves. This submittal contained a table of Category B and C safety-related valves which GPU Nuclear proposed to test.
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Follo ing the submittal of April 9,1984, GPU Nuclear submitted Technical Specification Change Requests 46, 49, and 51 which proposed significant reductions in the TMI-2 Technical Specifications. Based on these change requests, GPU Nuclear re-evaluated the valves listed in the April 9, 1984 letter. Accordingly, on May 15, 1986, GPU Nuclear submitted an exemption request for all Category B and C valves.
The violation was a direct result of a failure to implement the NRC requirement of April 27, 1981 to test all Category B and C valves in safety-related inservice systems at least once per 92 days. Upon identification of this deficiency on May 6,1986, a formal ISI program was developed and implemented to test those valves listed in the April 9, 1984 submittal with the exception of valves that are components of systems no longer related to plant safety. Operability for all valves tested has been confirmed per the requirements of the ASE Boiler and Pressure Vessel Code,Section XI.
As documented in Inspection Report 50-320/86-08, the failure to implement a formal ISI Program is considered to have minor safety significance as i
operability for most of the valves was demonstrated by conforming with the i
requirements of the Recovery Technical Specifications / Recovery Operations Plan and during operational / maintenance checks on plant systems. Additionally, Inspection Report 50-320/86-08 identified the failure to incorporate regulatory requirements in a timely manner as being representative of a breakdown of administrative controls, specifically inter-departmental connunications. GPU Nuclear concurs with this assessment. At the time of the April 27,1981 NRC letter, proper administrative controls and management supervision were lacking. However, GPU Nuclear believes that administrative controls and proper management supervision are currently in place to prevent a l
future occurrence of this type.
Specifically, the Licensing and Nuclear Safety Action item System is used by the TMI-2 Licensing Section to track all regulatory commitments so that they may be implemented in a timely fashion.
GPU Nuclear believes this system will ensure the prevention of future similar events and that full compliance has been achieved.
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