ML19262A095
| ML19262A095 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/25/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19262A094 | List: |
| References | |
| TASK-TF, TASK-TMR 50-320-79-10, NUDOCS 7910260342 | |
| Download: ML19262A095 (11) | |
Text
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APPENDD A NOTICE OF VIOLATION Metr ;clitan Edison Company Docket No. 50-320 Tris refers tc t*e investigstion concucted by an Of fice of Ins;ect'on anc Er.'crcerert Invest'gation Tea; at the Three Mile Island Nuclear Generating Static",, Middlet
,, Pennsylvania, of activities authorized by NRC License Ne.
D P :i-72.
Du +.; tne investigation conducted on March 28, 1979 through July 31. 19~9 (Inves-igation No. 50-223/79-10), the following apparent items of noncompliance we e icentified:
1.
Tecnnical Soecification 3/4.7.1, " Turbine Cycle," requires in Section 3.7.1.2, that three independent steam generator emergency feeowater pumps anc associated flow paths snall be operable during power operations, except: if one emergencv feedaater system is inoperable it must be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the plant must be in Hot Shutdcon within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Contrary to the above, for an undetermined period just prior to the reactor trip at approximately 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> on March 28, 1979, the flow patns to both stear generators were made inoperable by feedwater header isclation valve closure. (In addition, on January 3, February 26 and Parch 26, 1979, the flow paths from all three emergency feecaater pumps were simultaneously mace inoperable by feedwater header isolation valse closure during the performance of, and in accordance with, an improper sur.'eillance test procedure.)
This violation ccntributed to an accident.
(Civil Penalty S5,000) 2.
Tne severity and uniqueness of the accident which occurred at Tnree Mile Islan0 resultec in a marked reductior in the normal good nealth physics p a: tic.a onich are mandated by the NRC Regulaticas.
Under the circum-stances of an accident of this magnitude the NRC recogniz;, that in the interest. of reactor safety a de;3rture from normal health rhysics practices and standards may sometimes be mandated by the exigencies that exist dur'ng such conditions.
However, the NRC also believes that the licensee, wit-the resources available and taking into account the time frame a.ailable for conduct of safety-related functions, could have taken
&Ocitional measures to better control the overall health physics actions anc decisions which were made during the course of the accident.
The fol'owing items of noncompliance exemplify unacceptable degradation from hea'th physics practices pertaining to control of access to high radiation a*eas, conduct of radiation surveys, and personnel radiation expo ure rcr'tcring.
I' CFR 20.201, " Surveys," requires in Section (b) that each licensec
)
small take or cause to be made such surveys as may be necessary to ccmply with the regulations in 10 CFR 20.
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" "" " 3
not provided to the operate-fcr this entry.
This Contributed to the c;eratcr receiving a arale cocj dose et 2.170 rens.
Wren this dcse was accec to the operator's previous dose for the.lu.'rter, the operator's quarterly wncle body cose.was 3.870 rems as measured b) personnel dosi: retry devices; E.
On March 29, 1979, a Nuclear Engineer entered an area of the ouviliary building where the radiation level was greater than that which could be measurec by his portable survey instrument
( 2 F.J h r '
Failure to perforr a survey of the expcsure rate in this area contributed to the indivioual receiving a whole bod 3 cme o' 3.14 rems for this entry.
Wnen this dose was added to the er;inee 's previous dose for the quarter, the engineer's ou5rterly whole body dose was 4.175 rems as measured by personnel cosimetry devices; F.
On March 29, 1979, a Chemistry Foreman was permitted to repeatediy enter nign radiation areas and handle samples of highly radioactive reactor coolant.
This contributed to the Foreman receiving a whole body dose of 4.100 rems.
When this dose was added to the Foreman's previous dose for the quarter, the Foreman's quarterly whole body dose was 4.115 rems as measured by personnel dosimetry devices; G.
On March 29. 1979, a Chemistry Foreman and a Radiation Protection Foreman were parmitted to handle a highly radioactive reactor coolant sample without adecuate personnel monitoring and without first per-forming a survey of hand and forearm exposure rates.
Handling of this sample resulted in a calculated dose to the hands and forearms of the Chemistry Foreman of about 147 rems and a calculated dose to the hands and forearms of the Radiation Protection Foreman in the range of 44 to 54 rems, and H.
On March 28, 1979 and March 29, 1979, several individuals received skin contamination of the hand and other parts of the body suf'icient to cause exposure rates in the range of 20-100 mR/hr when measured with a hand-held survey instrument and no evaluation o' the dose to the skin of these individuals w's made.
Each day constitutes a separate violation, [ March 28 (A, B, C, and H),
March 29 ( A, B, C, D, E, F, 'i, and H), and March 30 (A and C)]; a civil pe Ity of 55,000 is imposed for each.
(Cumulative Civil Penalty 515,000) 3.
Technical Specification 6.5.1, " Plant Operations Review Committee,"
recuires: in Section C.5.1.6.a, that the Plant Operations Review Committee (PORC) review all procedures (and changes thereto) required by Technicai Specification 6.8 and any other procedure (or change) determined to affect nuclear safety.
1"m P00R ORENAL 2.
At various tires throughout the day of Marcn 25. 1979, the high
" essure injection syste was modified suc-tr.at the regu rec f'cw rates were nct raintained during continuing lo.: pressure ccncitions within the RCS fcllowing the period when the react:*
ccolant pumps were stopped and the high pressure injection system was the only rode availaole for the removal of core decay neat.
E.2 Erergency Procecure 2202-1.3, " Loss of Reactor Coolant / Reactor Coolant System Pressure," Revision 11, requires certain actions be taken fciloving the automatic initiation cf high pressure injection, including in Section E.3.1, tnat all ESF ecuio ent is ver:fied to be in its ESF position (capable of performing its intenced function).
Contrary to the above, during the period of approximately 0600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> until 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br /> on March 25, 1979, during continuing los pressure conditions witnin the RCS, the Core Flood System was removed from its ESF position (rendered inoperable) by closing both tank isola-tion valves.
[This portion of the ESF was inactivated auring a period when reduction of Reactor Coolant System pressure was not the immediate goal.
This removed from service this safety feature during a pericd when it could have been called upon.
In the course of the accident while attempting to depressurize to activate the deca) heat removal system NR: recogniced that it was necessary a isolate the ccre flood system and encouraged this action.
This citation does not apply to isolation during this attempt].
This violation contributed to an accident.
(Civil Penalty S5,000)
C.
Operating Procedure 2104-6.2, " Emergency Diesels and Auxiliaries,"
Revision 9, establishes the precedures for the control of the erergency diesel generators:
<ection 4.10, "Diesal Generato- - Automatic Start Upon Engineered Safety Features Actuation," states in the closing step, 4.10.6, that the unit can be shutdown after the Engineered Safeguards Feature actuation hai been cleared.
2.
Section 4.6, " Diesel Generator lA(lE) Shutdown to Emergency Standby," states in the closing step, 4.6.6, to place the diesei generator on standby in accordance with Section 4.2; Ind 3.
"ection 4.2, when completed, establishes conditions for automatically starting the diesels upon actuation of an Engineered Safeguards Feature (ESF) including requirements 1217 012 P00R ORGINA
Ccr;*a y to the above:
1.
Acequate critten proceaures were not estaniisned and implemente. in tra+ Secti:n 2.1 of Procequee 1004 for "ciementinc ne Emercency Plan lackec suf ficient soecificity anc faile; to result in a Site Emergency t.eing declared at apprcximately 0430 on March 28, 1979, even though primary system pressure had decreased to the coint where safety injection was automatically initiated anc a reactor building su~:p high level alarm exi'ted; and site emergency was not declared at 0535 hours0.00619 days <br />0.149 hours <br />8.845899e-4 weeks <br />2.035675e-4 months <br /> on March 28, 2.
n 1979, at whicn time Condition "e" cf Three Mile Island Emercerc3 ria, 1004 had occurred.
Inis is an infraction.
(Civil Penalty S4,000)
F.
Tr ee Mile Island Nuc' ar Station Health Physics Prccedure 167C.9, " Emergency Training and Emergency Drills," Revision 4, catec January 16, 197E:
1.
Identifies in Section 3.1, the on-site emergency job catogeries and requires that training programs for these categcries will be conducted on an annual (calendar year) basis; and 2.
Describes in Section 3.1.1 through 3.1.9, the training program for all on-site emergency job categories.
Contrary to the above, during calendar year 1978, not all individuals having emergency responsibilities were trained in that two Emergency Directors, one Accident Assessment individual, eight Radiological Monitoring Team Members, and 37 Repair Party Team Members had not received the specified training.
In addition on March 28, 1979, during an emergency, at least four individuals who were essigned as required members of a Radiological Monitoring Team anc seven individuals who were assigned as required members of a Repair Party Team per-formec emergency duties for which th3y were not trained.
Tr.is is an infraction.
(Civil Penalty 54,000)
G.
Station Administrative Procedere 1002, " Rules for the Protection of Encloyees Working on Electrical and Mechanical A;3a'atus," Revision 14, cequires in Section 4.3, 4.4 and 4.5 tnat on restoration of equipment to service, removed tags will have all required information entered the eon and then be suitably l '"> 1 /
013 P00R ORIGINAL.
Tnree Mile Island Nuclear Station Surveillance Procedure 1202-5.2', Re,isior 3, dated Decer;er 19, 1974, specifies tne method of calibration and requires that it be performed a nn u a '. iy.
Ccntrar; to the above, as of March 29, 1979, eight environmental samplers had not beer calibrate: since 1974.
This is an infraction.
(Civil Penalty 54,00u) 7.
Technical Specification 6.2, "Orgarization," states in Section 6.2.1 and 6.2.2 that the unit organization ana the o'garization of the corporate technical support staff shall be as shown on Figure 6.2-1.
Contrary to the above, on March 28, 1979, the organization of the unit and corporate technical support staff was different f rom that specified in Figure 6.2-1 in tnat:
A.
A position titled, " Superintendent of Administration and Technical Supoort was added to the organization on September 18, 1978 and filled on March 1, 1979, such that tne " Supervisor, Radiation Protection and Chemistry,"
reported to this new position rather than directly to the " Station Superintendent / Senior Unit Superintendent;"
and E.
Inere were two " Supervisor of Maintenance" positions, one for each unit, rather than one; and C.
A position titled " Superintendent of Maintenance" had been added such that the " Supervisors of Maintenance" report to this new position rather than directly to the
" Station Superintencent (Station Manager)/ Senior Unit Superintendent;" and D.
The position of " Chemical Supervisor" had been vacant since the issuance of the Technical Specifications.
On March 25, 1979 through March 3C, 1979, the above organizational discrepan.ies decreased the ef fectiveness of the licensee's respoise to the accident.
This is an infraction.
(Civil Penalty $3,000) 8.
Technical Specification 6.4 " Training," recuires that a retraining and replacement training program for the unit staff be maintained that meets or exceeds the requirements and recommendations of Section 5.5 of ANSI N18.1-1971.
P00RBRER 12 " o "
Inis is an infraction. (Civil Penalty 54,C00) 11.
10 CFR 50, Appendix E. Criterion X, " Inspection," requires that a prograr for inspection of activities cffecting quality shall be estaDlished and executed to verify conformance witn occumented instru:.:. ions, prececures and drawings for accomplisning the activity.
Three Mile Island Nuclear Station - Unit 2, Final Safety Analysis Report, Cnapter 17.2.15,Section X, requires that the inspection program include random observation of operations and functional testing by individuals independent of the activity being performed.
Procease GP 4014, "QQA Surveillance Program," Revision 0, requires independent observatien of activities affec'.ing quality to verify conformance with establisned requirements utilizing both inspection and auditing techniques..for compliance with written procedures and the Technical Speci-fications.
Contrary to the above, as of March 28, 1979, the normal operations surveillance testing activities had not been made subject to rudom and/or routine inspections by independent methods.
This is an infraction.
(rivil Penalty S3,000)
This Notice af Viola' ion is sent to Metropolitan Edison Company pursuant tc the provisions of 5'ction 2.201 of tne NRC's " Rules of Practice," Pa..t 2, Title 10 Code of Federal Regulat ons.
Metropolitan Edison Company is hereby i
requ" red to submit to this of fice within twenty (20) days of the receipt of this Nctice, a written statement or explanation in repiy, including for each item of noncompliance: (1) acmission or denial of the alleged items of non-co p'iance: (2) the reasons for the items of noncompliance if admitted; (3) the torrective steps which have been taken and the results achieved; (4) corrective steos which will be taken to avoid further items of noncom-1,s.Le; and, (5) the date when full compliance will be achieved.
The total cisil penalties for all items cited is 5725,000.
However, pursuant to Secticn 234 of the Atomic Energy Act of 1954, as amended (42 USC 2282), the total of civil penalties for any thirty day period cannot exceed 525,000.
Co ns equer.tly 5570,000 has been subtracted to redtce the total penalties to 525,000 for each 30 day period resulting in the total civil penalty herein prepcsed of 5155,000.
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