ML20236H911

Notice of Violation from Insp on 860825-1003 & 870608-16. Violations Noted:Listed Proposed Mods & Procedure Changes Important to Safety Not Adequately Reviewed.Hearing Svc List Encl

ML20236H911
Person / Time
Site:	Three Mile Island
Issue date:	07/29/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236H899	List: ML20236H895 ML20236H911 ML20236H928
References
50-289-87-08, 50-289-87-8, NUDOCS 8708050391
Download: ML20236H911 (3)

Text

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l-APPENDIX A ,

i NOTICE OF VIOLATION GPU Nuclear Corporation Docket No. 50-289 Three Mile Island, Unit No. 1 Licensee No. ORP-50 l

As a result of inspections conducted on August 25 to October 3, 1986, and June 8 - 16, 1987, apparent violations of NRC requirements were identified.

l In accordance with the " General Statement of Policy.and Procedure for NRC Enforcement Actions," 10 CFR Part 2 Appendix C, the violation is set forth below.

The 10 CFR 50.59(b) requires, in part, that records of changes (to the facility and procedures as described in the Safety Analysis Report) include a written safety evaluation which provides the basis for the determination that the change does not involve an unreviewed safety questions. Technical Specifica-tion (TS) 6.5.1.12 requires, in part, that individuals responsible for reviews of such changes shall render determinations in writing with regard to whether or not the changes constitute any unreviewed safety questions.

1. TS 6.5.1.3 requires that proposed modifications to unit structures, systems, and components shall be reviewed.

Contrary to the above, certain proposed modifications were not adequately reviewed as evidenced by the following:

a. As of September 5, 1986, Plant Engineering Modification 85-279-M authorized, as a " replacement-in-kind," the generic replacement throughout the plant of Fisher Series 3560 valve positioners from the original aluminum seat to a mechanical brass insert without adequate identification of where these positioners were located and used in the plant and without adequate evaluation that this replacement would not cause an unreviewed safety question. At least one of these posi-tioners had an important-to-safety function; namely, MS-V-6, steam pressure regulator for the steam-driven emergency feedwater (EFW) pump.

b. As of March 3, 1987, Revision 1 to the safety evaluations for modi-fications to the HSPS and EFW systems (BA No. 412024) did not indi-cate that all safety performance characteristics, such as fire pro-tection, electrical protection, and environment qualification, were reviewed for affect on safety by that revision.

2. TS 6.8.2 and 6.5.1.1 require that procedures and changes thereto which are important to safety shall be reviewed for adequacy.

B70B050391 B70729 PDR ADOCK 05000289 g PDR

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Appendix A 2 Contrary to the above, certain procedures and procedure changes important to safety were not adequately reviewed as evidenced by the following:

a. Several special temporary procedures and temporary procedure changes involving important-to-safety (ITS) systems were issued between

' January 5 and September 8, 1986, that described important-to-safety activities and were not classified ITS in accordance with then current licensee administrative controls and, consequently, they did not receive an. adequate technical review and, in some cases, received no documented safety review. These included, in-part, procedures for flushing a valve in the makeup and purification system, for testing an EFW pump, for diluting an intermediate cooling system, and for ,

testing leakage of a waste gas decay tank. (

Reference:

NRC Inspec-tion Report No. 60-289/86-14, paragraph 3.4.1(1) and (3), and Report No. 50-289/86-17, paragraph 6.2).

b. 'As of March 3, 1987, the Heat Sink Protection System (nuclear safety-related initiation and control system for the EFW system) functional (startup) test procedures were not classified ITS and, consequently, did not receive a documented safety review (reference:

NRC Inspection Report No. 50-289/87-06, paragraph 6.2.6).

c. As of September 1,1986, the safety evaluation for Revision 2 to Corporate Procedure 1000-ADM-1291.01, " Procedure for Nuclear Safety and Environmental Impact Review and Approval of Docu-ments," did not discuss whether the proposed changes conflicted with existing technical specifications. As a result, the new technical and safety review process implemented by this revi-sion does not require a (detailed) written determination that no unreviewed safety question exists for all tests / experiments and procedures classified as important to safety.

In the aggregate the above examples of failure to conduct adequate proposed modification and procedure reviews have been classified as a Severity Level IV Violation (Supplement 1).

Pursuant to the provision 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 in extending this response time.

OFFILIAL RECORD COPY IR TMIl 87 0005.0.0 11/29/80 i

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.i TMI-1 Hearing Service List Sheldon J Wolfe, Chairman Bruce W. Churchill Esquire Administrative Judge Shaw, Pittman, Potts & Trowbridge Atomic Safety & Licensing Board f _ael 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 Bcard Administrative Judge Panel Atomic Sciety & Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuc lear Regulatory Commission Washington, D.C. 20555 Wascington, 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 Common,ealth 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 1

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