ML20214P483

Notice of Violation from Insp on 860303-27 & 0707-11

ML20214P483
Person / Time
Site:	Three Mile Island
Issue date:	09/11/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214P480	List: ML20214P476 ML20214P483 ML20214P485
References
50-289-86-12, NUDOCS 8609230117
Download: ML20214P483 (5)

Text

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,. .a APPENDIX A NOTICE OF VIOLATION GPU Nuclear Corporation Docket No. 50-289 Three Mile Island, Unit No. 1 License No. DRP-50 During NRC Inspections conducted between March 3-27 and July 7-11, 1986,

' violations of NRC requirements were identified. In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions," ,

10 CFR Part 2 Appendix C, the violations are set forth below.

A. '10 CFR 50.59(b) states, in part, that, "... Licensee ... records [of changes in the facility or procedures as described in the safety analysis report] shall include a written safety evaluation which provides the basis for the determination that the change ... does not. involve an unreviewed safety question..."

1. Technical Functions Procedure EP-016, Revision 1-00, dated January 18, 1985, " Nuclear Safety / Environmental Impact Evalua-tion," Exhibit 3, paragraph 3.3, requires, in part, that the written safety evaluations for facility changes describe how the proposed change will or will not affect the safety functions by addressing concerns such as: (3.3.1) system performance; (3.3.3) natural phenomena with respect to seismic classification; (3.3.9) electrical isolation criteria; and, (3.3.11) single failure criteria.

Contrary to the above, licensee safety evaluations for various safety grade modifications did not fully address various safety performance functions as noted below.

As of March 27, 1986, lead shielding was installed on important-to-safety piping without a proper evaluation on system performance during a design basis seismic event.

As of March 26, 1986, the two-hour backup instrument air system for the Emergency Feedwater System (EFW) was susceptible to single failure.

2. Administrative Procedure 1001A, Revision 10, dated April 17, 1986, " Procedure Review and Approval," Figure AP 1001A-5 on procedure change safety evaluations, paragraph 2, requires, in part, that a determination be made that the procedure change does not cause an unreviewed safety question.

8609230117 DR 860911 ADOCK 05000289 9 PDR OFFICIAL RECORD COPY IR THIl 86 0003.0.0 08/28/86

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. . ~ Appendix A: 2 -.

Contrary to 'the above, as of March 27, 1986, safety evaluations related to EFW pump surveillance test _(SP 1303-11.42) changes-did not adequately determine that an unreviewed safety question existed,-in that the surveillance test provided a test lineup-p .that was inconsistent with the applicable section of the updated safety analysis report.

This is a Severity IV Violation (Supplement I).

B. The110 CFR 50 Appendix B Criterion II and the NRC approved Quality Assurance Plan (QAP), dated November 1985, establish overall quality-assurance program requirements for the design and construction of safety-related structures, systems, and components. To implement these require-ments, the QAP Appendix C commits to the' implementation of-Regulatory Guide 1.64, Revision 2, June 1976,-and ANSI N45.2.11,1974, on " Quality Assurance Requirements for the Design of Nuclear Power Plants."'

1. ANSI N45.2.11, paragraphs 3.1 and 4.2, require, in part, that applicable design inputs and bases be identified in sufficient detail, documented, and their selection reviewed and approved.

Contrary to the above, as of March-27,1986:

The design input review and approval process permitted battery sizing calculations to be performed using a minimum temperature for which no basis was referenced. (Actual battery temperatures were lower than the minimum used in the calculation). Also, other design input data used in the battery sizing calculation, such as pump and valve starting and running current, lacked sufficient references to permit the complete verification of the calculations.

The design input review and approval process permitted the use of preliminary, unverified design input as a basis for fuse changes in dc power distribution panels.

2. ANSI N45.2.11, paragraph 5.1.3, requires, in part, that systematic

' methods be established for communicating needed design informa-tion across external design interfat.es.

Contrary to the above, as of March 27, 1986, design input.

associated with sizing of regulating valves installed in the two-hour backup supply air system was provided by the licensee to an architect engineer but was subsequently changed without notifying the affected design organization.

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Appendix A 3-

3. ANSI N45.2.11, paragraph 6.1, requires, in part, that measures shall be applied to verify the adequacy of design. Technical Functions' Division Procedure 5000-ADM-7311.02 (EP-009), Revi-sion 1-00, dated July 31, 1985, " Design Verification," requires, in part, the verification of calculations, the preparation of ,

verification checklists, and the verification of system designs.

Contrary to the above, as of March 27, 1986, design verification requirements had not been fully adhered to, as noted below:

Three engineering calculations, Calculation No.

1101X-322F-165 - Flow Rates for Two-Hour Backup Air Supply System; Calculation No. 1101X-322F-424 EFW System Resistance; and Calculation No. 1302X-5320-A50 - Shielding stress, had no calculation verifications performed.

Three design verifications, Calculation No. 1101X-3228-003

- Air Consumption by EF-V-30 Valves; Calculation No.

1101X-322F-157 - EFW Pump Turbine Relief Valve Setpoint; and Calculation No. 1101X-3228-004 - Air consumption by MS-V-6, did not have required verification checklists prepared.

System Design Descriptions 424A, B, C, D, and E, Division I and II, involving the EFW system, its backup instrument air supply, and supporting instrumentation, had not been design verified.

Nine shielding installations were installed prior to the calculations to support the shielding having been verified.

4. ANSI N45.2.11, paragraph 6.3, requires, in part, adequate preoperational testing be specified. Technical Functions Procedure 5000-ADM-7335.01 (SP-001), Revision 0-00, dated November 15, 1984, "Startup and Test Program and Test Require-ments," paragraph 4.7.1 requires, in part, that functional test procedures verify that modifications perform their intended functions.

Contrary to the above, as of March 27, 1986, post-modification testing of the two-hour backup air supply mccification did not confirm that the modification produced expected results per the design basis and did not have acceptance criteria consistent with the system design basis.

This is a Severity IV Violation (Supplement I).

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. Appendix A 4 C. -The 10 CFR 50 Appendix B Criterion XVI and the NRC-approved Quality Assurance Plan (QAP), dated November 1,1985, sections 8.1.1 and 8.2.1 require, in part, that the licensee assure conditions adverse to quality; such as, deficiencies, deviations, and nonconformances, are promptly corrected.

Contrary to the above, as of March 27, 1986, the licensee did not assure that the below-noted conditions adverse to quality were promptly corrected.

At various times between October 3, 1985, and March 27, 1986, out-of-specification data for important-to-safety systems existed on auxiliary operator log sheets without being properly identified as such and without being properly explained as required by licensee administrative controls.

Design documents, which included control room and engineering drawings for various important-to-safety systems, either (1) were not updated in accordance with licensee administrative control or (2) contained errors.

This is a Severity IV Violation (Supplement I).

D. The 10 CFR 50 Appendix B, Criterion V requires that activities affecting quality shall be prescribed by instructions, procedures or drawings and shall be accomplished in accordance with those instructions, procedures, or drawings.

1. Technical Functions Procedure 5000-ADM-7350.05 (EMP-002), Revision 0-00, dated September 13, 1985,, " Mini-Mods," in Exhibit 2, para-graphs 2 and 7, require, in part, the documentation of sections of the safety analysis report that need updating for important-to-safety modifications. Exhibit 2 also requires the documentation of varinus design information.

Contrary to the above, as of March 27, 1986, the documents associated with two mini-mods (additional limit switches for the fuel handling crane and removal of instrument air line from EFW pump recirculation valves) were incorrectly marked as no change being required to the FSAR when, in fact, changes to the FSAk were required. For these and other important-to-safety mini-mods, not all the design information required to be addressed by EMP-002 was addressed.

2. Installation specification for lead shielding around letdown prefilters, MU-F2A and 2B, required that the center of gravity of the top blocks be no more than 12 inches off the floor, the blocks be no closer than 2 feet to important-to-safety (ITS) equipment due to seismic considerations, and that a warning sign be installed identifying the 2 foot requirement.

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. Appendix A 5 Contrary to the above, as of March 27, 1986, the lead shielding installation on MU-F2A and 2B had the top block center of gravity 15 inches off the floor in some locations. ITS valves SF-V-77 and SF-V-71 were located within 6 inches and 19 inches of the blocks,- respectively, and no warning sign was installed.

3. Design Calculation No. 609-0293, Revision 0 " Bottle Rack for RM-13h" (EFW Two-Hour Backup Instrument Air (TBIA) Subsystem),

required that the air bottle chain restraints preclude vertical movement with turnbuckles attached to the chain to assure adequate tension. The chain and turnbuckle connection were to be made by open "S" chain links, which were to be closed after installation.

Contrary to the above, as of March 27, 1986, the TBIA air bottle restraints had no turnbuckles, certain restraints were loose, and "S" links were not closed.

.This is a Severity IV Violation (Supplement I).

Pursuant to the provision of 10 CFR 2.201, GPU Nuclear Corporation is hereby required to submit to this office within 30 days of the date of the letter transmitting this Notice, a written statement of explanation in reply, inclu-ding for each violation: (1) the corrective steps which have been taken and the results achieved; (2) the 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, conside. ration will be given to extending this response time.

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