ML20234B792
| ML20234B792 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/18/1987 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 5211-87-2116, GL-87-02, GL-87-2, NUDOCS 8707060208 | |
| Download: ML20234B792 (6) | |
Text
a GPU Nuclear Corporation 99 Nuclear
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Middletown, Pennsylvania 17057-0191 717 944 7621 1
f TELEX 84 2386 Writer's Direct Dial Number:
q June 18, 1987 5211-87-2116 l
Mr. William V. Johnston, Acting Director Division of Reactor Safety Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Johnston:
Three Mile Island Nuclear Station Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Response to Notice of Violation (Inspection Report 50-289/87-01)
Attached is the GPUN response to the Notice of Violation contained in Inspection Report 50-289/87-01 which concerns the mounting of two (2) environmentally qualified pressure transmitters.
An extension of the due date for submitting this response was granted by the NRC as discussed with the Senior NRC Resident Inspector, R. Conte, on June 10, 1987.
Sincerely, 8707060208 870618 PDR ADOCK 0500 9
D. H k 11 G
Vice President and Director, TMI-1 JA/fkg 4847 /0895A 9
Attachments Swornangsubscribedtobeforeme this. //
day of Qux L.,1987.
cc:
R. Conte - USNRC G. Edison - USNRC W. Russell - USNRC jh /. [ w w M A N b w e E:$"$E":usE FIDDLETOWN BOT:0, DAUPHfM C0tW LY cgs;ZS;0W D;PinD JUNE 1l, Dr3 retsber, PeuntyNants Associ:tlan of fto+.arles GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation 1T -C \\
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x ATTACHMENT 1 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," 10CFR Part 2, Appendix C (Enforcement Policy) (1986), the following violation was identified:
10CFR50, 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-li 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.
Response to the Violation Corrective Action /Results Achieved The RCS wide range pressure transmitters (RC-3A-PT3 and RC-3B-PT4) provide input to the Eatergency Safeguards Actuation System (ESAS) to provide a signal at 1600 psig for HPI cooling following a LOCA or SBLOCA.
These transmitters are Foxboro model EllGH-HINM2 which are mounted with a single U-bolt arrangement as shown from the Foxboro Ell vendor manual no.MI 020-220 page 3 (attached).
(Note that these transmitters differ from the Foxboro NEll transmitters to which vendor manual no. MI 020-165 applies.) The TMI-l design as shown in the I
attached photograph employs two U-bolts which is a more rigid design than employed in the vendor instruction and were installed in accordance with approved site procedures during original plant construction.
On February 19, 1987, NRC issued Generic Letter 87-02 concerning Seismic Qualification of Equipment in Operating Plants whose construction permit pre-dated 1972. The purpose of this letter was to resolve USI-A46 concerning upgrading the older plants to new seismic criteria using experience data as opposed to IEEE 344-1975 where applicable.
These transmitters were evaluated in March 1987 using the methods of Generic Letter 87-02. The report concluded that these transmitters fell within the experience data base (including mounting) ana are similar in design to those transmitters mounted by one U-bolt which survived earthquakes far in excess of those which would be experienced at TMI-l under SSE conditions of.12g (e.g., Coalinga, CA in 1933
.60g),
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F' The cause of the looseness of the bottom U-bolts is indeterminate. The unit was shutdown at the time of the inspection and only the nuts on these two transmitters were loose.
In late January, the bottom U-bolts were tighten to conform with the original design installation.
Other transmitters with like mountings were checked and were all found to have secure U-bolts.
Corrective Steps to Avoid Further Violation i
GPUN is a part of the Seismic Qualification Utility Group which is working with NRC to assure that all equipment necessary to achieve hot safe shutdown is seismically qualified in accordance with Generic Letter-87-02. This program will include a review of mountings and anchorages.
Date of Full Compliance Full compliance has been achieved.
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HI 020-220 Page 3 InstallationWirina RemoteAmolifier For installation of power. supply and wiring of If amplifier is not contained within recetver loop, see Instruction HI 020-126 (4 to transmitter housing. it may be located up to 20 mA output) or Instruction HI 020-125 (10 to 150 m (500 ft) from transmitter. Its ambient 50 mA output),
temperature limits are -40 and +80'C (-40 and
+180*F).
Refer to figures below.
$nb n nh 4 HOLE 311 mm 10 4 in) DI A.
- 1. Transmitter cover must be hand tightened only to provide watertight seal.
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PURPOSE OR 8
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- 2. Transmitter may be mounted in any position.
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- 3. After transmitter is mounted, tighten all
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- 4. Pipe may be clamped to another pipe, or g
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- 5. U-bolt secures assembly to DN 50 or 2 in 4 lo2,,
with horizontal pipe.
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pipe. U-bolt may be revolved 90' for use 203 _ '
TAPPED FOR 1/2 CONDulT l
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Figure 1:
The Foxboro transmitter shown above is attached through its mounting plate by U-bolts to a short steel arm bolted into the concrete wall.
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