ML20214G039
| ML20214G039 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/15/1987 |
| From: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| To: | Russell W NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 5211-87-2098, NUDOCS 8705260389 | |
| Download: ML20214G039 (3) | |
Text
OPU Nuclear NggIgf 100 interpace Parkway Parsippany, New Jersey 07054 201 263-6500 TELEX 136-482 Writer's Direct Dial Number:
May 15,1987 5211-87-2098 U.S. Nuclear Regulatory Comission Attn: Document Control Desk Washington, DC 20555 Attention: Mr. William T. Russell Region I, Regional Administrator Gentlemen:
Three Mile Island Nuclear Station, Unit 1, (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Response to Notice of Violation NRC Investigation Report No. 1-84-021 Attached is the GPUN response to the subject Notice of Violation.
Sincerely, N
.b P. R. Clark President PRC:RJM:jh Sworn and subscribed to before me this 15th 4669g day of flay,1987 Attachment cc:
R. Conte, USNRC
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Page 1 of 2 GPUN LTR. 5211-87-2098-ATTACHMENT As a result of.the NRC-Office of Investigation (0I)' Report (0I Report'
~
No'.84-021) - dated October 11, 1985, and in accordance with NRC enforcesent
. policy (10.CFR Part 2, Appendix C. (1986)), the following violation was
-identified.
Criterion XVI of 10 CFR 50, Appendix B, requires in part that~ measures-shall be established to ensure that conditions adverse ~to quality such as failures, malfunctions, and. defective material and equipment are promptly identified and corrected. Further, the measures shall assure.
that the'cause of the condition,is-determined and corrective action is taken to. preclude repetition..The corrective actions taken~shall be documented and reported to appropriate levels of management.
Contrary toLthe above, adequate. corrective actions were not.taken in response to'an audit of the EQ program conducied (ay GPUN)-between March 26 and April 1,1981 in that some of the progrmumatic deficiencies identified during the audit such as a lack of documentation' to support fi!e auditability and a lack of procedures still existed as of February 1, 1984 when,they were again identified during a (GPUN)~QA
-assessment of the EQ program.
Response to Violation lGPU. Nuclear has provided an extensive discussion of this matter during the December 4,1986 Enforcement Conference -(No.- 50-289/86-24).
This conference
- is summarized in NRC letter to Mr. H. Hukill of GPUN dated December _18,-
1986.' -The details of the issues will therefore not be discussed herein,-
4 however a summary is provided.
(1) Disposition of-Violation GPUN agrees with the violation in that not all QA audit findings were closed out in a prompt manner.
(2) Reasons for the Violation The root causes of this deficiency were inadequate:
(1) prioritization of GPUN resources, (2) performance of the EQ Supervisor, (3) understanding of NRC requirements by the EQ group, (4) supervision of
'the EQ group by Management and (5) escalation of concerns with the
. e do not believe that apparent sensitivity closeout of audit findings.
W to QA findings noted in the NOV transmittal letter was a significant contributing factor to this violation.
It has been specific Corporate policy for all GPUN Divisions to work meaningfully to properly close out initial QA audit findings.' In this particular case, the data shows the bulk of the audit findings were, in fact, closed out.
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r Page 2 of 2 GPUN LTR. 5211-07-2098 (3) Corrective Steps /Results Achieved The corrective actions include:
(1) A new'and improved organization, staff, and leadership for the EQ-
- program, (2)
Improved management attention to the EQ program, (3)
Instructions to personnel to be more timely-in responding to QA, (4) More oversight of contractors work, (The original EQ work was performed by a contractor.)
(5) : Improved review, processing, and signoff of licensing correspondence, (6)
Improved method of processing audit findings s'o that they are better understood, (7) A formal escalation procedure modified to ensure timely resolution of QA audit findings, and (8) Additicnal attention to improving the quality and timeliness of QA status reports on findings.
These corrective actions hsve been implemented and/or are part of our-continuing effort to improve GPUN activities. As a result of these actions, we have witnessed improved timeliness in closing audit findings, as discussed at the December 4, 1986 Enforcement Conference.
Procedures to' support the EQ program and escalation of QA Audits findings have been implemented. The auditability of EQ files continues to improve as understanding and interpretation of the requirements evolves within the industry and the NRC.
It is concluded that appropriate actions have been taken to prevent recurrence.
(4)_ Corrective Steps to Avoid Further Violations Within GPUN there is increased Management attention on open audit findings to assure they are dispositioned promptly. There is also increased attention to major programs such as EQ to ensure that proper resources are applied with strong and effective management.
(5) Date of Full' Compliance Corrective actions necessary for full compliance had been completed or implemented by December 31, 1986.
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