ML20210R927
| ML20210R927 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/20/1997 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Langenbach J GENERAL PUBLIC UTILITIES CORP. |
| Shared Package | |
| ML20210R935 | List: |
| References | |
| 50-289-97-05, 50-289-97-06, 50-289-97-5, 50-289-97-6, CAL-1-97-08, CAL-1-97-8, NUDOCS 9709040184 | |
| Download: ML20210R927 (2) | |
Text
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August 20, 1997 Mr. James W. Langenbach Vice President and Director, TMI GPU Nuclear Corporation Three Mile Island Nuclear Station P. O. Box 480 Middletown, PA 17057 0191
SUBJECT:
RESPONSE TO CONFIRMATORY ACTION LETTER 197 008, DATED MARCH 4,1997
Dear Mr. ' angenbach:
This acknowledges receipt of your letter, dated April 30,1997, responding to actions 1 and 2 requested in our Confirmatory Action Letter 1 97-008. In addition to reviewing the information supplied in your letter, we reviewed selected material non-conformance reports and written engineering evaluation and disposition records, as described in NRC Integrated Inspection Report No. 50 289/97 05. The inspector found that the licensee's corrective actions were acceptable.
This also acknowledges receipt of your letter, dated July 21,1997, responding to actions 3 and 4 requested in our Confirmatory Action Letter. These actions were addressed at a management meeting held on July 16,1997. The purpose of the meeting was to discuss the GPU Nuclear evaluation of the assessment of the equipment downgrading process, as documented in NRC Integrated Inspection Report No. 50 289/97-06.
Our inspection and meeting, along with your letters, is sufficient basis for us to conclude you have satisfied the requested actions contained in our Confirmatory Action Letter.
Sincerely, h
Hubert J. Miller Regional Administrator Docket No.: 50 289 i-l
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Mr. James W. Langenbach 2
cc:
E. L. Blake, Shaw, Pittman, Potts and Trowbridge (Legal Counsel for GPUN)
J. C. Fornicola, Director, Licensing and Regulatory Affairs M. J. Ross, Director, Operations and Maintenance D. Smith, PDMS Manager TMI Alert (TMIA)
J. S. Wetmore, Manager, TMl Regulatory Affairs Commonwealth of Pennsylvania Distribn11oln Regiosi l Docket Room (with concurrences)
Nuclear Safety information Center (NSIC)
PUBLIC NRC Resident inspector H. Miller, RA l
T. Kenny, DRS P. Eselgroth, DRP i
D. Haverkamp, DRP l
A. Keatley, DRP M. Oprendek, DRP B. Fewell, ORA W. Dean, OEDO P. Milano, NRR, PDI 3 B. Buckley, PM, NRR, PDI 3 L. Thonus, NRR S. Weiss, NRR R. Correia, NRR F. Talbot, NRR DOCDESK Inspection Program Branch, NRR (IPAS)
D. Holody, ORA DOCUMENT NAME:
A: CAL 97008 is receive a copy of this document. Ind6cate in the boa: 'C' = Copy without ettechmentienclosure
'E' = Copy with attachynt!snelosure
'N' = No copy 0FFICE Rl/DRP 3,_,
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NAME DHAVERKAMPX /d P6 ///A0TH CHEHLif1r HMILLTR
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/97 0FFICIAL RECORD COPY
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March 4, 1997 Licenso No. DPR 16 Licenso No. DPR 50 CAL No.197 008 Mr. T. Gary Broughton Frosident and Chief Executive Officer GPU Nuclear Corporation 1 Upper Pond Road Parsippany, NJ 07054 Door Mr. Broughton:
SUBJECT:
CONFIRMATORY ACTION LETTER 197 008 During an Inspection covering the period January 6 to March 2,1997, NRC Inspectors questioned the quality classification of selected plant components at Throo Milo Island (TMI) Nuclear Station Unit 1. Subsequently, following liconaco review, the NRC datormined that numerous safety related components were improperly downgraded from tho " nuclear safety related" classification to a lower tier classification without appropriato l
sofoty evaluations or other supporting engincoring documentation. Theso equipment classification downgrados woro initiated by GPU Nuclear and affected both TMI and Oyster Crook facilities.
The NRC is concerned about the potential implications of the Inappropriate equipment classification downgrados. Moreover, we are concerned about the poor implomontation of l
the component classification process, as well as related weaknesses in procedure adherence and communications. We are also concerned about the inoffective oversight of the process by management, especially related to not taking prompt action to ovaluato and resolve program problems identified by your own quality assurance activities. Because of the considerablo extent of the process weaknosses, we also question the broader implications of those problems for other engineering processos.
Accordingly, pursuant to a tolophono conversation betwoon Mr. Arthur Rono and others of your staff and Mssrs. Eugono Kelly and Potor Eselgroth of my staff, on March 3,1997,it is our understanding that you would take soveralimmediato and long term correctivo actions.
Specifically, you committed to:
1.
Immodlately tako stops to precludo additional inappropriato instances of equipment classification downgrados by:
a.
stopping. work on further programmatic equipment classification downgrades pending proceduro and training upgrados, and N
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T. G. Broughton 2
b.
establishing a process to review planned day to-day maintenance and modification work involving equipmont that was ro classified to assure that parts of the correct quality classification components are used.
By Antil 30.1997:
2.
Determino the impact of the equipment clast.ification downgrado program, as imptomonted, at TMl and Oyster Creek.
You should report the completion of this itorn by lottor addressed to the Regional Administrator, NRC Roglon I, dated on or before April 30,1997.
Dv July 1.1997:
3.
Perform an assessment, involving outsido contractors and at least one outsido member of your General Offico Review Board, of the equipment classification downgrading process to determino:
a.
the root causes of the weaknessos associated with the establishmont and implomontation of the process and appropriato correctivo actions, and b.
why past quality assurance findings in this area woro not addressed in a timely manner.
4.
Based on the results of your assessment, datormino what assessments and changes to other engineering processos are needed.
You should be prepared to discuss your evaluation of the assessment in a management mooting with Region I staff on or before July 18,1997.
Pursuant to Section 182 of the Atomic Energy Act,42 U.S.C. 2232, and 10 CFR 2.204, you are required to:
1.
Notify me immodlately if your understanding differs from that set forth above.
2.
Notify me if for any reason you cannot complete the actions within the speciflod scheduto and advise mo in writing of your modified scheduto in advance of the chango.
3.
Notify me in writing when v m have completed the actions addressed in this Confirmatory Action Letter.
Issuance of this Confirmatory Action Letter does not preclude issuanco of an Order formalizing the above commitments or requiring other actions on the part of the licensee.
Nor does it preclude the NRC from taking enforcement action for violations of NRC requirements that may have prompted the issuance of this letter, in addition, failure to take the actions addressed in this Confirmatory Action Lotter may result in enforcement action.
T. G. Broughton 3
The response directed by this letter are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub.L. 96 611.
In accordance with 10 CFR 2.700 of the NRC's " Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Public Document Roorn.
Sincerely, 7A ibert J. Miller egional Administrator Docket Nos. 60 219,50 289 License Nos. DPR 16, DPR 60 cc:
M. J. Cross, Acting Vice President and Director - TMI E. L. Blake, Shaw, Pittman, Potts and Trowbridge (Legal Counsel for GPUN)
Commonwealth of Pennsylvania J. C. Fornicola, Director, Licensing and Regulatory Affairs TMI Alert (TMIA)
J. S. Wetmore, Manager, TMl Regulatory Aff airs M. B. Roche, Vice President and Director Oyster Creek G. Busch, Manager, Site Licensing, Oyster Creek M. Laggart, Manager, Corporate Licensing State of New Jersey
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Telflf s44 7621 April 30,1997 6710-97 2169 Mr. liubert J. Miller USNRC Region 1 Administrator 475 Allendale Road King of Prussia, PA 19406 1415
Subject:
Three Mile Island Nuclear Station, Unit 1 (TMI 1)
DPR 50/ Docket No. 50-289 Response to Item 2 of Confirmatory Action Letter (CAL) 1 97 008 Quality Classification of Selated Plant Components at TMI l
Dear Mr. Miller:
I Item 2 in Confirmatory Action Letter 197 008 reads as follows:
" 2. Determine the impact of the equipment classification downgrade prograrn, as implernented, at TMI and Oyster Creek.
You should report the completion of this item by letter addressed to the Regional Administrator, NRC Region 1, dated on or before April 30,1997. "
The purpose of this letter is to provide a documented response for TMl 1 to this specific item.
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Mr. Ilubert Miller Page 2 As part of our immediate corrective action in response to the issues raised on the QCL, steps were initiated to stop work on further programmatic equipment classification downgrades pending procedure and training upgrades, and to establish a process to review planned day to-day maintenance and modification work involving equipment that was downgraded in order to assure that parts of the correct quality classification are used.
The downgraded items can be placed in the following three categories: 1) items initially classified as " nuclear safety related"(NSR) and downgraded to " regulatory required"(IUl) or "Other with QA", or "Other without QA"-there were 1129 items in this category; 2) items initially classified as RR and downgraded to "Other with QA" there were 3834 iterns in this category; and 3) items initially classified as RR and downgraded to "Other without QA"-there were 1978 items in this category.
For the first category ofitems that were initially classified as NSR, item lists were posted to prevent unreviewed activities until safety reviews could be conducted which confirmed the i
downgraded classification, or aflirmed the original NSR classification. The safety reviews on all 1129 items in this category have been completed. Of the 1129 items that were initially classified as NSR,71 were aflirmed as NSR and the remainder are reclassified as RR or Other. A complete review ol' pans usca m the maintenance of these 71 components during the downgrade time period disclosed that 11 parts without basic component qualification were used. All 11 parts are commercial grade items and are not nuclear unique. The impact of the equipment classification _
downgrade program on previously classified NSR items at TMI has been determined by evaluating the operability of the specific components that were affected._ Operability reviews have been
~ completed and have concluded that none of the affected NSR components are inoperable now nor were they inoperable during the period that they were reclassified liowever, the 11 parts without basic component qualification require corrective actions to ensure full conformance to their quality classification requirements. These corrective actions and their consequences have been evaluated and there is reasonable assurance that all components will remain operable until the required corrective actions are completed.
All 3834 items in the second category that were downgraded from RR to "Other with OA" have _
had their classification returned to RR. The impact of this downgrade was reviewed and
~ determined to have no negative impact' on past or future operation of plant systems for the following reasons. Although the 3834 items were downgraded, the materials and parts for the downgraded items were not progranunatically downgraded and many of the parts which were available for use remained at the RR classification. An extensive review of parts available to Maintenance revealed that less than 400 non-OA parts were available from enmnonent " Bill of Materials" for use in components that received maintenance The downgraded classification maintained the acllyities associated with the equipment within QA scope, and required corrective and preventative maintenance activities to be performed using QA scope procedures. The procedures which were used require a comparison of replacement parts with existing pans and require gst maintenance testing to verif that the e uipment will.
n.
Based on tT6iieTacis3c ~ conclude that the operability of the affected components is not impacted s
now nor was it during tlie penoa of time when they were at the lower classification.
- The Auxiliary & Fuel llandling Duilding Ventilation system has been declared inoperable due to quality ctassification concerns and has been addressed in LER 97 o04.
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Mr. Ilubert Miller Page 3 There are 1978 items in the third category that were downgraded from RR to "Other without QA" which have been evaluated. The evaluation resulted irt649 items being returned to RR and the rest reclassified as Other. The impact of the downgrade on the 649 items was determined to have no riegative impact on past or future operation of plant systems for the following reasons. The materials and parts for the downgraded components were not programmatically downgraded and many remained at the RR classification. An extensive review revealed that less than $0 non-QA puilable from component " Bill of Materials" to Maintenance for use in components that received maintenance. The existing maintenance procedures require a comparison of replacement parts with existing parts and post maintenance testina to verify that the equipment will perform its intended function. We conclude that the operability of the affected components is not impacted now nor during the period ~that they were reclassified.
GpU Nuclear took action to ensure that QCL deficiencies with a potential to impact plant safety were addressed. For the components with the greatest potential impact on safety (NSR), safety reviews concluded no affect on the operability of those components. Most materials and parts for downgraded RR components remained at the RR classification. This, combined with the controls l
employed through maintenance procedures, provides reasonable assurance that repaired components are operable and reliable.
Based on the above, GpUN has concluded that although deficiencies existed in the QCL, appropriate action was taken to minirnize any affect on safe plant operation including the implementation of corrective action.
If you should have any questions concerning the information in this letter, please contact Mr. Adam Miller, Regulatory Affairs Department, at 717-948-8128.
Sincerely, hghld.
ames W. Langenbach Vice President and Director, TM1 AWM
. cc:
Document Control Desk TMI Senior Resident Inspector Director Division of Reactor Safety
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4-July 11,1997 Mr. James Langenbach Vice President and Director, TMl GPU Nuclear Corporation Three Mile Island Nuclear Station l
Post Office Box 480
?
Middletown, PA 17057 0191
SUBJECT:
NRC INTEGRATED INSPECTION REPORT NO. 50 289/97 05
Dear Mr. Langenbach:
On June 15,1997, the NRC completed an inspection at your Three Mile Island 1 reactor facility. The enclosed report presents the results of that inspection.
Overall, plant operations were conducted in a safe, conservative manner. The shsp.ng cask activities associated with six fuel pins from Unit 1 were very well controlled by maintenance, radiological controls, and engineering personnel.
4 The review of your corrective actions related to the quality classification list (OCL) and component downgrade program determined that you were effective in implementing and verifying meaningfulimprovements to the QCL program. Engineering procedure, EP 011, was revised to provide a detailed standard for the OCL program and classification of equipment important to safety. For example, EP-011 was revised to require a written i
safety determination / safety evaluation when the quality classification of a component is changed from a higher to a lower classification. GPU Nuclear took prompt action to ensure that OCL deficiencies with a potential to impact plant safety were addressed satisfactorily.
and that there was no affect on the operability of safety related equipment.
in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Public Docurnent Room (PDR).
Sincerely, Original Signed By:
Peter W. Eselgroth, Chief Projects Branch No. 7 Division of Reactor Projects Docket No.: 50 289 License No.: DPR 50
Enclosure:
- 1. NRC Inspection Report No. 50 289/97 05
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EXECUTIVE
SUMMARY
Three Mile island Nuclear Power Station Report No. 50 289/97 05 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a 7 week period of resident inspection and the Regional review of the fuel cask shipment for Unit 1. The results of the engineering core inspection and the motor operated valve program will be documented in separate correspondence.
l Plant Onorations The engineered safeguards actuation system (ESAS) configuration, procedures, and t
test requirements were consistent between the plant hardware and system documentation to support the design safety function. A positive example of TMI's -
program to maintain the plant design basis current ana up to date, was noted for the ESAS UFSAR enhancements and corrections submitted by the cystem enginent (Section 02.1).
The complex ESAS surveillance test procedure verified that the safety system design requirements were satisfied and minimized unnecessary challengta to the emergency equipment. The surveillance tests were coordinated and completed without an impact on plant operation or safety equipment availability (Section 02.1 ).
Maintenance The fuel pin shipping cask activities were very well controlled by maintenance, radiological controls, and engineering personnel. Supervisory oversight was maintained throughout the evolution (Section M1.1).
The experienced l&C technician applied excellent troubleshooting and calibration techniques throughout the repair and surveillance activities for the RM G 25 radiation monitor. During the review of the RM-G 25 safety tag application the detector drain valve and inlet isolation valve tags were found to be attached to the
- wrong valve. The safety impact was minimal because bc 'h valves were closed and tagged. The operations personnelimmediately correcte0 h tagged valves and nitiated a corrective action process (CAP) form to evalut 9. me root cause for the self checking error (Section M1.1).
EOSIDAndDS GPU's immediate corrective actions addressed the QCL downgrade deficiencies and
- were verified by nuclear safety assessment to be effective. OCL activities were
-stopped until the engineering procedure EP-011, " Methodology for Preparing the Quality Classification List," was ' revised and training was provided to all personnel involved with the OCL process (Section E3.1).
11 w
EP 011, " Methodology for Preparing the Quality Classification List," was revised to formalize the OCL process and included written detailed standards related to component and program changes. For example, EP 011, section 4.5.1,
" Downgrades," was revised to require a written safety determination / safety evaluation when the quality classification of a component is changed from a higher to a lower classification, in addition, the procedure was added to the safety review program described by Technical Specification No. 6.5.1.12 and a safety evaluation was written to document the bases for the revision (Section E3.1).
GPU Nuclear took action to ensure that OCL deficiencies with a potential to impact plant safety were addressed. For the components with the greatest potential impact on safety (NSR), safety reviews concluded that there was no effect on the operability of those components. Even though component documentation lowered the classification, the component spare parts remained at the original higher classification. This combined with the quality assurance controls employed through maintenance procedures, provided reasonable assurance that repaired components remained operable (Section E3.1).
ELantsuppp11 In the area of plant support, we found that your preparation, planning, and coordination of a spent fuel shipment was very good. Although appropriate emergency response information was provided in a timely manner in response to a mini-drill scenario involving a postulated accident with a fuel shipment, the shif t supervisor did not maintain a constant communication link until all of the needed I
information was provided to the responder.
l 1
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in i
TABLE OF CONTENTS EX EC UTIVE SU M M ARY............................................. Il TA B L E O F C O N T E NT S.............................................. IV
- l. Operations
................................................... 1 01 Conduct of Operations (71707).............................. 1 02 Operational Status of Facilities and Equipment 1
02.1 Engineered Safety Feature System Walkdown............... 1 II. M ain t e n a nc e................................................... 3 M1 Conduct of Malntenance (62707,61726)....................... 3 I l l. E ng in e e ri n g................................................... 4 E3 Engineering Procedures and Documentation (37551,92903) 4 E3.1 - Equipment Quality Classification Documentation related to CAL No. 9 7 0081t em s 1 & 2............................... 4 IV. Plant Support
................................................. 7 R8 Miscellaneous RP&C lssues (86759,92904).....................
7-V.
Man ageme nt Meetings........................................... 9 X1 Exit Meeting Summary.................................... 9 X2-Engineering Pre Decisional Enforcement Conference Summary........ 9 PARTI AL LIST OF PERSONS CONTACTED............................... 10 ITEMS OPENED, CLOSED, AND DISCUSSED............................. ' 11 LIST O F ACRO NYM S U SED...........................................
12 iv I
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4 and controls (l&C) technician's radiation monitor / detector troubleshooting and calibr tion techniques were very proficient and experienced. During the review of the RM G 25 safety tag application, No. 97 0538, an error was noted by the inspector. The tags for the detector drain valvo VA V 33 and the detector inlet isolation valve VA V 32 were placed on the wrong component. The safety impact was minimal because both valves were closed and tagged. The operations personnelimmediately corrected the valve tags and initiated a corrective action process (CAP) form to evaluate the root cause and associated corrective actions related to the error. This vlotation of the station tagging procedure is of minor significance and is being treated as a Non Cited Violation, consistent with Section IV of the NRC Enforcement Policy. (NCV 50 289/97005 02) c.
Conclusions The fuel pin shipping cask activities were very well controlled by maintenance, radiological controls, and engineering personnel. Supervisory oversight was maintained throughout the evolution.
The experienced l&C technician applied excellent troubleshooting and calibration techniques throughout the repair and surveillance activities for the RM G 25 radiation monitor. During the review of the RM G 25 safety tag application the detector drain valve and inlet isolation valve tags were found to be attached to the wrong valve. The safety impact was minimal because both valves were closed and tagged. The operations personnel immedi:,tely corrected the tagged valves and initiated a corrective action process (CAP) form to evaluate the root cause for the self checking error.
Ill. Ennineering E3 Engineering Procedures and Documentation (37551,92903)
E3.1 Equipment Quality Classification Documentation related to CAL No. 97 008 Items 1&2 a.
Insoection Scooe The inspectors reviewed the equipment quality classification list (OCL) documentation related to confirmatory action letter (CAL) No.97-008,ltems No.1 & 2. The CAL commitments included taking immediate actions to preclude additional inappropriate equipment downgrades and to determine the impact of the equipment downgrade program at TMI. The QCL immediate and short term corrective actions were completed by GPU and documented in a letter to the NRC on April 30,1997.
b.
Observations and Findinas The' inspectors reviewed the documentation related to the OCL corrective actions. The nuclear safety assessment (NSA) department issued a stop work notice, No. NSA TMI 97-001, Rev.1, on March 1,1997, to prevent any additional QCL program downgrades until proper corrective actions were completed. Also, the Maintenance Director issued a
5 memorandum and a list of all down graded components that were in the generation maintenance system (GMS 2) computer system prior to the stop work order. The sponantalrLQuasilon were temporarily upgraded to.nucjaar_sainly.related (NSR) until material non conformance report's]MNCRs) or6ineering evaluationbwere completed to approve the proper clEsification. NSA also verified that the immediate corrective actions were incorporated and effective. Because of the potentialimpact on safe plant operation.
GPU engineering evaluated and corrected the QCL deficiencies related to the downgrade of NSR components. A data base review revealed that 1129 components were downgraded to regulatory required (RR) or "Other" (non safety related). GPU determined that 71 components, of the 1129 total, should have remained at the NSR classification. The 71 components were returned to the NSR status and a complete review of parts used in the maintenance and modification of the components was performed for the downgrade time frame. Of the 71 components,11 had non safety grade parts installed.
The QV department initiated MNCRs to evaluate and document the acceptability and operability of the 11 components. The inspectors reviewed the MNCR documentation associated with all 11 components. Each component was entered into the corrective action process (CAP) data base to ensure that the corrective actions were tracked to completion. Three of the components installed in the safety related river water systems were replaced with NSR parts. An emergency feedwater steam control valve, MS V 13B, was analyzed and found exceptable and will be replaced during a planned outage with and NSR component. Six components related to the main feedwater and diesel generators were scheduled for a formal commercial grade dedication to document acceptability. One component, a diesel building temperature controller, was installed after performance of a commercial grade dedication in 1994. Acwritterrengideering evalditibiisrid~ disposition was included in each.MNCR package to provide.a bases _for eacitcomponent_sE_f5r applicationf"Tlie~ documentation was detailed, complete and provided a sound bases (equipment operability.
s in addition to the NSR downgrades, a number of RR components were downgraded to "Other with quality assurance (QA) processet, applied (3834 items)" or "Other without QA applied (1978 items)." All 3834 items that were downgraded from RR to "Other with QA" have had their classification returned to RR. The inspector reviewed a sample of the RR downgraded items in the GMS 2 computer data base. All component records reviewed determined that the components were returned to the RR classification as stated in the April 30th letter. The GPU evaluation of the downgraded components determined that there was no negative impact on past or future operation of plant systems for the following reasons. Although the 3834 items were downgraded, the materials and parts for the downgraded items were not programmatically downgraded and many of the parts which were available for use remained at the RR classification. During the classification downgrading process activities associated with the equipment were maintained within QA scope, and required corrective and preventative maintenance activitics were performed using QA program procedures. The procedures which were used required a comparison of replacement parts with existing parts and required post maintenance' testing to verify that the equipment would perform its intended function.
6 GPU evaluated the 1978 items that were downgraded from HR to "Other without QA" to determine and document the proper component classification. The evaluation resulted in 649 items being returned to RR and the rest reclassified as Other. The impact of the downgrade on the 649 items was determined to have no negative impact on past or future operation of plant systems for the following reasons. The materials and parts for the downgraded components were not programmatically downgraded and many remained at the RR classification. The approved malntenance procedures required a comparison of replacement parts with existing parts and post maintenance testing to verify that the equipment would perform its intended function.
Based on these f acts, GPU concluded that the operability of the affected components was not impacted during the period of time when they were at the lower classification. The inspector's review of the documentation associated with the RR downgrades did not reveal any operability concerns.
The inspector reviewed the content and implementation of engineering procedure EP 011,
" Methodology for Preparing the Quality Classification List." The corporate Engineering Division procedure was revised on April 29,1997, and training was provided to all personnelinvolved with the OCL process. The procedure was added to the safety review program described by TS 6.5.1.12 and safety evaluation No. SE 945100 099 documented the bases for the revision. The new procedure has formalized the OCL process and included written detailed standards related to component and progreni changes. For example, EP 011, section 4.5.1, " Downgrades," was revised to require a written safety determination / safety evaluation when the quality classification of a component is changed from a higher to a lower classification. The definition of regulatory required (RR) components was clarified in the procedure and " Exhibit 9A" provided a list of regulatory
- references that would result in an RR classification level. The applicability of the procedure was changed to reflect the Intent of the program quality controls, c.
Conclusions GPU's immediate corrective actions addressed the OCL downgrade deficiencies and were verifled by NSA to be effective. OCL activities were stopped until the engineering procedure EP 011, " Methodology for Preparing the Quality Classification List," was revised and training was provided to all personnelinvolved with the OCL process.
EP 011, " Methodology for Preparing the Quality Classification List," was revised to formalize the QCL process and included written detailed standards related to component and program changes. For example, EP 011, section 4.5.1,
- Downgrades," was revised to require a written safety determination / safety evaluation when the quality classification of a component is changed from a higher to a lower classification in addition, the procedure was added to the safety review program described by TS 6.5.1.12 and a safety evaluation was written to document the bases for the revision.
l GPU Nuclear took action to' ensure that QCL deficiencies with a potential to impict plant safety were addressed. For the NSR components with the greatest potentialimpact on safety, safety reviews concluded that there was no effect on the operability of those components. Most materials and parts for downgraded components remained at the
7 previous classification. This combined with the quality assurance controls employed through maintenance procedures, provided reasonable assurance that repaired components remained operable. The TMl corrective actions were sufficient to conclude that confirmatory action letter No. 97 008,ltems No.1 & 2, were addressed saticf actorily.
IV. Plant Support R8 Miscellaneous RP&C lasues (80759,92904)
R8,1 Fuel Sh:oment a.
Backaround and insoection Scone (86750)
GPU made an arrangement with GE Nuclear Vallecitos Nuclear Center, in Pleasanton, Californla, to perform diagnostic testing on specific fuel pins to investigate crud buildup and local fuel rod ciadding damage. On June 6,1997, six fuel pins were sh pped from Three Mile Island Nuclear Plant to GE Nuclear Vallecitos Nuclear Center, in Pleasanton, California. An inspection was performed to determine if adequate precautions and preparations had been taken to safety ship the six spent fuel pins. Information was gathered through direct observations of vehicle loading and shipment preparations; performance of independent radiological surveys; reviews of shipping paperwork; discussions with cognizant personnel; and the conduct of a mini-emergency response information drill.
b.
Qbj!prvations and Findinas The six fuel pins had previously been placed inside a canister that was contained inside a type B shipping cask for transporte. tion. The inspector directly observed the loading of the shipping cask onto the transport trailer; installation of impact limiters; installation of a personnel barrier; and final vehicle transport inspections. Then evolutions were well coordinated and showed evidence of effective planning. Only minor problems were encountered during shipment preparat;ons, and licensee staff responded immediately to correct the problems. For example, a stripped bolt hole thread on the transport trailer was repaired to allow the personnel barrier to be installed, and a GPU mechanic reconnected a broken electrical wire to repair ths transport trailer running lights. Tha inspector observed the performance of rariiological surveys on the cask and transport venicle, and performed independent radiation surveys. Radiation and contcmination levels were well below the requirements listed :n 49 CFR ') art 173.441 and Part 173.443, and the inspector's survey results closely matched radiation survey data obtained by the radiological controls staff.
Department of Transportation (DOT) Yellow lil labels were placed on two sides of the cipping cask, and " radioactive" placards were used on the transport vehicle as required by DOT for highway route controlled quantity (HRCQ) shipments.
The inspector also reviewed the preparation of shipping papers and noted that appropriate information was included in the shipping paperwork package. Examples included a bill of lading; basic description of shipment; radionuclide data; shipper's certification; certificate of compliance for the shipping cask; and a 24-hour emergency response telephone number.
.