ML20214E259
| ML20214E259 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/11/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20214E253 | List: |
| References | |
| 50-289-87-01, 50-289-87-1, NUDOCS 8705220020 | |
| Download: ML20214E259 (4) | |
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APPENDIX A NOTICE OF VIOLATION GPU Nuclear Corporation Docket No. 50-289 Three Mile Island, Unit 1 License No. DPR-50 As a result of the Equipment Environmental Qualification inspection conducted on January 12-16 and January 20-21, 1987, and in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement Policy) (1986), the following violation was identified:
10 CFR 50, Appendix B, Criterion V states, in part, that: " Activities affecting quality shall be prescribed by documented instructions... and shall be accomplished in accordance with these instructions..."
Vendor manual no. 020-165 (page 2) specifies a special mounting bracket for use in seismic applications.
Contrary to the above, on January 20, 1987 the inspector identified Foxboro (Model E-11 GH) Transmitter Nos. RC-3A-PT4 and RC-38-PT3 mounted without the special mounting bracket but mounted on a vertical pipe with two U-bolts.
The bottom U-bolt was loose on both instruments.
Engineering justification for use of U-bolts instead of the vendor specified seismic mount was not available.
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 violations; and (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending this response time.
OFFICIAL RECORD COPY IR THIl 87 0003.0.0 0700220020 070011 04/29/87 PDH ADOCK 0000 9
Appendix 8 Three Mile Island Unit 1 Docket No. 50-289/87-01 Potential Enforcement Items As a result of the equipment qualification (EQ) inspection on January 12-21, 1987, the following items have been identified as Potential Enforcement Items. (Paragraph references are to detailed portions of the inspection report.)
1.
Contrary to paragraph (J) of 10 CFR 50.49, at the time of this inspection, GPUN did not demonstrate that the EQ files were maintained in an auditable form to permit verification that each item of electrical equipment important to safety was qualified for its application.
(Paragraph 4.9.1, 50-289/87-01-01) 2.
Contrary to paragraph (d)(1) of 10 CFR 50.49, at the time of this inspection GPUN did not adequately demonstrate qualification of the Limitorque Switch cam (color coded black) identified by the licensee in M0V nos. RC-V-3 and WDG-V-3.
Prior to the end of this inspection the licensee issued DCN-048169 consisting of additional vendor data and engineering analysis generated during this inspection to address the issue.
The EQ file, EQTI-103, 104 and 105 will be revised to include this information.
(Paragraph 4.10.2 50-289/87-01-03) 3.
Contrary to section 2.2 (7) of NUREG-0588, Category I requirements, at the time of this inspection, GPUN did not adequately demonstrate that the effects of cable insulation resistance for Rockbestos cable had been considered with respect to instrument accuracy requirements.
Prior to the end of this inspection the licensee issued a Design Change Notice, OCN-048180, consisting of an engineering analysis generated during this inspection to address the issue. This data was reviewed and found to be unacceptable since the licensee analysis is based on cable not used at TMI-1 and a similarity analysis was not available. DCN-056832 was issued to address NRC concerns on similarity. The EQ file, EQTI-150 will be revised to include this data.
(Paragraph 4.10.3,50-289/87-01-04) 4.
Contrary to paragraph (d)(1) of 10 CFR 50.49, at the time of this inspection, GpVN did not adequately demonstrate that the effects of cable insulation resistance for Brand Rex cable had been considered with respect to instrument accuracy requirements.
Prior to the end of this inspection the licensee issued a Design Change Notice, DCN-048165, consisting of an engineering analyses generated during this inspection to address the issue.
The EQ file, EQTI-153 will be revised t) include this data.
(Paragraph 4.10.9,50-289/87-01-09)
a Appendix B 2
5.
Contrary to paragraph (f)(1) of 10 CFR 50.49, at the time of this inspection, GPUN did not adequately demonstrate qualification of the Static-0-Ring Pressure Switches.
Supporting data or analysis comparing test specimen versus installed components was not present in the EQ file. Prior to the end of this inspection the licensee issued a Design Change Notice, DCN-048148, consisting of additional data generated during this inspection to address the issue. The EQ file, EGTI-117 will be updated to include this information.
(Paragraph 4.10.13,50-289/87-01-13) 6.
Contrary to paragraph (d)(1) of 10 CFR 50.49, at the time of this inspec-tion, GPUN did not adequately demonstrate qualification of the Kerite Splice nor did the licensee address disposition of test anomalies.
Prior to the end of this inspection the Itcensee issued a Design Change Notice, DCN-048138, containing additional data generated during this inspection to address the issue.
The EQ file, EQTI-126 will be updated to include this information. (Paragraph 4.10.12,50-289/87-01-12) 7.
Contrary to section 5.2 of 00R Guidelines, at the time of this inspection, GPUN did not adequately demonstrate qualification of Foxboro transmitters.
The EQ file lacked performance criteria used to evaluate significant results of Steam and Radiation tests and temperature measurement errors effect on instrument accuracy not addressed.
Prior to the end of this inspection the licensee issued a Design Change Notice, DCN-048164, containing additional data generated during this inspection to address the issue.
The EQ file, EQTI-122 and the SCEW sheet will be revised to reflect this information.
(Paragraph 4.10.5,50-289/87-01-06) 8.
Contrary to section 2.1(3) and 2.2 of NUREG-0588, Category I requirements, at the time of this inspection, GPUN did not adequately demonstrate qualification of the Weed RTD's. The EQ file lacked instrument error analysis showing acceptability of RTD testing and temperature measurement effect on instrument accuracy. Traceability and similarity analysis was not performed in comparing the test specimen versus the installed components. DCN-048191 was issued to address NRC concerns. The EQ file, EQTI-1 will be revised to include this data.
(paragraph 4.10.4, 50-289/87-01-05) 0FFICIAL i:FCORD COPY IR TM11 87 0006.0.0 05/07/87
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O grattons.
18 50-289.
TMI-1 Hearing Service List Sheldon J. Wolfe, Chairman Bruce W. Churchill, Esquire Administrative Judge Shaw, Pittman, Potts & Trowbridge Atomic Safety & Licensing Board Panel 2300 N Street, N.W.
U.S. Nuclear Regulatory Commission Washington, D.C.
20037 Washington, D.C.
20555 Dr. Oscar H. Paris Atomic Safety & Licensing Board Administrative Judge Panel Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Frederick J. Shon Atomic Safety & Licensing Appeal Administrative Judge Board Panel Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Joanne Doroshow, Esquire Docketing & Service Section Three Mile Island Alert, Inc.
Office of the Secretary 315 Peffer Street U.S. Nuclear Regulatory Commission Harrrisburg, PA 17102 Washington, D.C.
20555 Louise Bradford Mary E. Wagner, Esquire 1011 Green Street Office of Executive Legal Director Harrisburg, PA 17102 U.S. Nuclear Regulatory Commission Washington, DC 20555 Thomas Y. Au USNRC Assistant Counsel Commonwealth Resident Inspector of Pennsylvania Box 311 Dept of Environmental Resources Middletown, PA 17057 Bureau of Environmental Resources Room 505, Executive House P. O. Box 2357 Harrisburg, PA 17120 i
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APPENDIX A NOTICE OF VIOLATION GPU Nuclear Corporation Docket No.
50-289 Three Mile Island, Unit 1 License No. DPR-50 As a result of the Equipment Environmental Qualification inspection conducted on January 12-16 and January 20-21, 1987, and in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement Policy) (1986), the following violation was identified:
10 CFR 50, Appredix B, Criterion V states, in part, that: " Activities affecting quality shall be prescribed by documented instructions... and shall be accomplished in accordance with these instructions..."
Vendor manual no. 020-165 (page 2) specifies a special mounting bracket for use in seismic applications.
Contrary to the above, on January 20, 1987 the inspector identified Foxboro (Model E-11 GH) Transmitter Nos. RC-3A-PT4 and RC-38-PT3 mounted without the special mounting bracket but mounted on a vertical pipe with two U-bolts. The bottom U-bolt was loose on both instruments.
Engineering justification for use of U-bolts instead of the vendor specified seismic mount was not available.
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 violations; 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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Appendix B Three Mile Island Unit 1 Docket No. 50-289/87-01 Potential Enforcement Items As a result of the equipment qualification (EQ) inspection on January 12-21, 1987, the following items have been identified as Potential Enforcement Items. (Paragraph references are to detailed portions of the inspection report.)
1.
Contrary to paragraph (J) of 10 CFR 50.49, at the time of this inspection, GPUN did not demonstrate that the EQ files were maintained in an auditable form to permit verification that each item of electrical equipment important to safety was qualified for its application.
(Paragraph 4.9.1, 50-289/87-01-01) 2.
Contrary to paragraph (d)(1) of 10 CFR 50.49, at the time of this inspection GPUN did not adequately demonstrate qualification of the Limitorque Switch cam (color coded black) identified by the licensee in MOV nos. RC-V-3 and WDG-V-3.
Prior to the end of this inspection the licensee issued DCN-048169 consisting of additional vendor data and engineering analysis generated during this inspection to address the issue.
The EQ file, EQTI-103, 104 and 105 will be revised to include this information.
(Paragraph 4.10.2 50-289/87-01-03) 3.
Contrary to section 2.2 (7) of NUREG-0588, Category I requirements, at the time of this inspection, GPUN did not adequately oemonstrate that the effects of cable insulation resistance for Rockbestos cable had been considered with respect to instrument accuracy requirements.
Prior to the end of this inspection the licensee issued a Design Change Notice, DCN-048180, consisting of an engineering analysis generated during this inspection to address the issue. This data was reviewed and found to be unacceptable since the licensee analysis is based on cable not used at TMI-1 and a similarity analysis was not available.
OCN-056832 was issued to address NRC concerns on similarity.
The EQ file, EQTI-150 will be revised to include this data.
(Paragraph 4.10.3,50-289/87-01-04) 4.
Contrary to paragraph (d)(1) of 10 CFR 50.49, at the time of this inspection, GPUN did not adequately demonstrate that the effects of cable insulation resistance for Brand Rex cable had been considered with respect to instrument accuracy requirements.
Prior to the end of this inspection the licensee issued a Design Change Notice, DCN-048165, consisting of an engineering analyses generated during this inspection to address the issue. The EQ file, EQTI-153 will be revised to include this data.
(Paragraph 4.10.9,50-289/87-01-09)
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j Appendix B 2
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5.
Contrary to paragraph (f)(1) of 10 CFR 50.49, at the time of this inspection, GPUN did not adequately demonstrate qualification of the Static-0-Ring Pressure Switches. Supporting data or analysis comparing test specimen versus installed components was not present in the EQ file. Prior to the end of this inspection the licensee issued a Design Change Notice, DCN-048148, consisting of additional data generated during this inspection to address the issue.
The EQ file, EGTI-117 will be updated to include this information.
(Paragraph 4.10.13,50-289/87-01-13) 6.
Contrary to paragraph (d)(1) of 10 CFR 50.49, at the time of this inspec-tion, GPUN did not adequately demonstrate qualification of the Kerite Splice nor did the licensee address disposition of test anomalies.
Prior to the end of this inspection the licensee issued a Design Change Notice, DCN-048138, containing additional data generated during this inspection to address the issue. The EQ file, EQTI-126 will be updated to include this information. (Paragraph 4.10.12,50-289/87-01-12) 7.
Contrary to section 5.2 of 00R Guidelines, at the time of this inspection, GpVN did not adequately demonstrate qualifb stion of Foxboro transmitters.
The EQ file lacked performance criteria usu to evaluate significant results of Steam and Radiation tests and temperature measurement errors effect on instrument accuracy not addressed.
Prior to the end of this inspection the licensee issued a Design Change Notice, DCN-048164, containing additional data generated during this inspection to address the issue. The EQ file, EQTI-122 and the SCEW sheet will be revised to reflect this information.
(Paragraph 4.10.5,50-289/87-01-06) 8.
Contrary to section 2.1(3) and 2.2 of NUREG-0588, Category I requirements, at the time of this inspection, GPUN did not adequately demonstrate qualification of the Weed RTD's. The EQ file lacked instrument error analysis showing acceptability of RTD testing and temperature measurement effect on instrument accuracy.
Traceability and similarity analysis was not performed in comparing the test specimen versus the installed components. OCN-048191 was issued to address NRC concerns. The EQ file, EQTI-1 will be revised to include this data.
(paragraph 4.10.4, 50-289/87-01-05)
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