ML19261E868
| ML19261E868 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/28/1977 |
| From: | Arnold R METROPOLITAN EDISON CO. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19261E865 | List: |
| References | |
| GQL-0030, GQL-30, NUDOCS 7910170908 | |
| Download: ML19261E868 (3) | |
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C METROPOLITAN EDISON COMPANY =s:=:ur aninnt enu:urur::::cse:.ur:c.,
POST OFFICE BOX 542 READING, PENNSYLVANI A 19603 TELEPHONE 215 - 929-3601 January 28, 1977 GQL 0030 Mr. Eldon J. Brunner, Chief Reactor Operations & Nuclear Support Branch U. S. Nuclear Regulatory Co:=tission 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Mr. Brunner:
Three Mile Island Nuclear Station, Unit I (TMI-1)
Docket No. 50-289 Operation License No. DPR-50 Inspection I 3 port No. 50-289/76-26 This letter and the attached enclosure are in response to your inspection letter of December 21, 1976, concerning Mr. K. Plumlee's inspection of TMI-1 and the resultant finding of these apparent violations.
Sincerely,
,O R. C. Arnold Vice President RCA:DGM:daf E1 closure 1483 064 -
39101'r902 o
Metropolitan Edison Ccmpany Three Mile Island Nuclear Station Unit 1 (TMI-1) g t
Docket No. 50-289 License No. DPR-50 Inspection No. 76-26 RESPONSE TO DESCRIPTION OF APPARENT VIOLATION Management Controls That Prevent Recurrences For all apparent violations, the cognizant Department Head reviews the circunstances surrounding the particular item of nonecmpliance.
The Department Head discusses the apparent violations with key members of his staff and then with the PORC.
Recc=mendations are made to the Unit Superintendent in the way of corrective measures to prevent this type of noncompliance in the future.
Recc=mendations have been made in the areas of training, procedural changes, design changes, and counseling of individuals involved with a particular item of noncompliance.
For items of noncompliance which have occurred previously, as in the case of apparent violations A and B, a review occurs to determine why the corrective action that was previously i=plemented did not prevent another occurrence.
If the initial corrective action is thought to be the best possible solution it is again implemented. However, as done for the apparent violations in the inspection report, additional corrective action, as described in each response, was implemented.
Apparent Violation A:
10 CFR 20.203 (b) " Caution signs, labels, signals and centrols" requires that i
such radiation area be conspicuously posted with a sign or signs bearing the radiation caution sy=bol and the words " CAUTION RADIATION AREA".
Contrary to this requirement, an area accessible to personnel in which a radiation level of 15 cres/hr was measured near the precoat recirculation piping was not posted as a radiation area when inspected on November 16, 1976.
This item is recurrent in that sinilar items of noncompliance were brought to your attention in letters dated April 9, 1975, and August 2, 1976.
Response to Acrarent Violation A :
The area in question had been surveyed by a radiatien protection technician approximately three hours prior to the inspection and found to be less than 5 cren/hr.
Subsequent to the survey, a reactor coolant bleed tank had been placed en recirculation thrcugh the precoat filters, causing the 15 mres/hr level discovered during the inspection.
A memorandum has been distributed detailing the need for cecperation and ce==unicatien between the Cperations, Maintenance and Health Physics Depa tment rega-ding plant cperations and maintenan e activities which can cause variations in radiation levels. The area in questien has been per-'aently pcsted and rcped off as an intermittent radiation area and as such, requires a radiation work permit prior to entry, and full ccmpliance has been achieved.
Additionally, as operating or maintenance evolutions are identified which can cause variations in radiaticn levels, precedural changes vill be made to insure the notification cf the Radiaticn Protection Department to insure proper radiation surveys are performed.
1483 '0h65
Apparent' Violation B:
g Technical Specification Section 6.11 requires adherence to procedures for all operations involving personnel radiation exposures, and Health Physics Procedure 17h9 requires quarterly calibrations of PAC hS survey instrunents, plus or minus 1 weeks.
Contrary to the above, two PAC-hS survey instru= ercs were identified on November 19, 1976, Serial Nos.1357 and 2752, that were available for use and had not been calibrated since July 1h, 1976, and were more than three weeks overdue for calibration.
This item is recurrent in that similar items of nonco=pliance were brought to your attention in letters dated April 20 and September 21, 1976.
Resconse to Arnarent Violation B:
Upon completion of the calibration procedure for the two FAC-hS survey instruments on July lb,1976, the radiation protection technician involved inadvertantly added four months rather than three to determine the new due date for compliance with the quarterly calibration requirement.
This produced a due date of November 1k, 1976 with a late date of November 25, 1976. This entry was the firrt into the new ccmputer based tracking system, which uses a computer to autcmatically add the correct time interval to compute the new calibration due date. Both PAC-hS survey instru=ents have been calibrated and we are now in full compliance.
Apparent Violation C:
10 CFR 30.k1 (c) " Transfer of byproduct =aterial" requires that before transferring
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byproduct material the licensee transferring the material shall verify that the transferee's license authorized the receipt of the type, form, and quantity of byproduct material to be transferred.
Contrary to this requirement, a pu=p vas shipped on April 6,1976, to a repair shop and the transferee's license did not authorize the receipt or possession of the byproduct =aterials present in the shipment.
Response to Arrarent Violation C:
Station Health Physics Procedure 1618 " Shipment of Radioactive Materials, DOT Regulations, has been revised to include the require =ent that the license of the recipient be reviewed by a radiation protection supervisors prior to signing the shipping form, and va are now in full compliance.
Additionally, instruction has been given to all radiation protection supervisors regarding the need to review completely the recipiends license to insure that they may receive the type and quantity of material being shipped and that a current license is maintained en file at Three ? Ele Island.
1483 066
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