ML20215N212

Forwards Response to Forwarding Notice of Violation & Proposed Imposition of Civil Penalty.Util Agrees That Violation Occurred & Will Forward Payment of Proposed Fine Under Separate Cover

ML20215N212
Person / Time
Site:	Crane
Issue date:	10/29/1986
From:	Phyllis Clark GENERAL PUBLIC UTILITIES CORP.
To:	Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
0116P, 116P, 4410-86-L-0176, 4410-86-L-176, NUDOCS 8611040444
Download: ML20215N212 (4)

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GPU Nuclear Corporation NggIgf Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057-0191 717 944-7621 TELEX 84 2386 Writer's Direct Dial Number:

(717) 948-8461 4410-86-L-0176 Document ID Oll6P October 29, 1986 Office of Inspection and Enforcement Attn: James M. Taylor - Director US Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Taylor:

Three Mile Island Nuclear Station, Unit 2 (TMI-2)

Operating License No. DPR-73 Docket No. 50-320 Response to Notice of Violation and Proposed Imposition of Civil Penalties This responds to your letter of September 29, 1986, which forwarded a Notice of Violation and Proposed Imposition of Civil Penalty. Your action is based on the findings of an investigation by the NRC Office of Investigations which concluded that applicable GPU Nuclear procedures were violated during the installation of hand release mechanisms on the polar crane main hoist brakes.

In addition, you stated that in reaching your conclusion, you considered the reports prepared by Kennedy P. Richardson, submitted on January 15, 1986, and Edwin H. Steir, submltted on February 28, 1986.

GPU Nuclear agrees that the Violation did occur and will forward payment of the proposed fine of $40,000 under separate cover.

The attachment to this letter provides the GPU Nuclear response to the Notice of Violation.

Sincerely, fua:

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Clark (D o President er

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Regional Administrator, Office of I&E - Dr. T. E. Murley i

L Director, THI-2 Cleanup Project Directorate, Dr. W. D. Travers No

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GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation

NRC NOTICE OF V10LATION Technical Specification, Section 6.8.1.g, in effect for activities at TMI-2 during the period up to October 31, 1983, required written procedures to be established, implemented and maintained covering REC 0VERY MODE activities, including those activities which could increase the likelihood of failures in systems important to nuclear safety.

Administrative Procedure AP 1021, " Engineering Change Memorandum (ECM),"

states in paragraph 4.0 that the "The ECM is the traveler by which proposed plant tie-in, betterment and modification packages'are assembled, reviewed and coordinated with GPU 's site organizations for their effects on the existing plant systems, components, and structures."

Administrative Procedure AP 1043, "Hork Authorization Procedure," establishes a means by which proposed changes to TMI-2 are initiated, reviewed, and approved in accordance with plant Technical Specifications.

It requires a Work Permit to be issued as the document to authorize initiation of work proposed by an ECM and to track work through completion, turnover, test and final records retention.

Contrary to the above, the licensee did not fully implement the requirements ^

of this Technical Specification for clean up activities at -TMI-2 in particular for those activities associated with refurbishment of the Reactor Building Polar Crane as evidenced by the fact that sometime prior to November, 1983 a modification was made to the main hoist brakes of the polar crane without using the required GPU Nuclear-approved ECM or Work Permit to add a hand release mechanism not present on the original brakes.

This hand release mechanism also added an additional function to the main hoist brakes.

GPU NUCLEAR RESPONSE GPU Nuclear acknowledges that the events cited above did occur. GPU Nuclear letters 4410-84-L-0157 dated October 5, 1984 and 4410-84-L-0169 dated October 8, 1984 originally reported the improper installation of the hand release mechanism on the main hoist brakes of the polar crane.

These letters, as supplemented by GPU Nuclear letters 4410-84-L-0177 dated October 12, 1984; 4410-84-L-0181 dated October 18, 1984; 4410-84-L-0220 dated December 14, 1984; 4410-84-L-0224 dated December 19, 1984; and 4410-85-L-0016 dated January 8, 1985, described the causes of the violation and the corrective actions taken to avoid similar occurrences.

The adequacy of this investigation was documented in the January 9, 1985 NRC letter, B.J. Snyder to F.R. Standerfer, which concluded that the GPU Nuclear investigation into the matter of the installation of the hand release mechanism was complete and adequate and that the crane had been demonstrated to be operable and safe to use for load conditions. Although some open items remained as a result of the NRC January 9, 1985 letter, none related to the addition of the hand release mechanism nor, as stated in the January 9, 1985 letter, adversely affected the ability of the crane to operate in a safe manner.

Therefore, it can be concluded that full compliance was achieved on January 9, 1985.

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An additional issue which warrants comment by GPU Nuclear is the assertion that the violation was "apparently willful." Our inquiry into tnis matter does not support your conclusion.

In particular, the TMI-2 Report prepared by i

Edwin H. Steir found a number of procedural deficiencies associated with the 4

installation of the brake releases, but concluded "The evidence does not show l

that anyone recognized that the installation of brake releases on the polar i

crane constituted modifications under either GPW Nuclear or Bechtel procedures until after August 1984." GPU Nuclear continues to support this. conclusion i

and remains steadfast in the view that violation of the applicable procedures was not willful.

The record demonstrates GPU Nuclear has consistently, attempted to ensure that its appro'.ed procedures be followed at TMI-2 and has,_

responded promptly to evidence of any deficiencies in procedural compilance.

However, debate on this issue serves no useful purpose at this late date and GPU' Nuclear does not intend to pursue it further.

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ATTACHMENT 4410-86-L-0176 October 29, 1986 METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER AND LIGHT COMPANY PENNSYLVANIA ELECTRIC COMPANY GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION Three Mlle Island Nuclear Station, Unit 2 (THI-2)

Operating License No. DPR-73 Docket No. 50-320 Notice of Violation This letter is submitted in response to the Nuclear Regulatory Commission's letter of September 29, 1986, which forwarded a Notice of Violation and Proposed Imposition of Civil Penalty concerning polar crane modifications.

All statements contained in this response have been reviewed and all such statements made and matters set forth therein are true and correct to the best of my knowledge, information, and belief.

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. Clark P esident Signed and sworn before me this 29th day of October, 1986.

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