ML19275A968

Advises of Problem W/Tech Spec 4.1.1.A,App B Re Fish Impingement Study.Licensee Fish Sampling & Counting Methods Adequate Pending Tech Spec Revision & Clarification.Nrc & Util 741220,750120,750210 & Two Undated Ltrs Encl

ML19275A968
Person / Time
Site:	Crane
Issue date:	04/18/1975
From:	Higginbotham L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Regan W US ATOMIC ENERGY COMMISSION (AEC)
References
NUDOCS 7911010747
Download: ML19275A968 (3)

Text

-

b L(-

_a APR 181975

1. )

/

)

P

s 9

f W. H. Regan, Chief, Environmental Projects Branch 4 Division of Reactor Licensing, NRR AFFEEDII E TECHNICAL SPECITICATION 4.1.1.A FOR THREE MILE ISLAND This memorandum is to bring to your attention a problem em have had with this technical specification; a tech spec which I understand is going to be revised. I have summarized the problem below and enclosed l

' sopies of some pertimeet correspondence. I have discussed this subject with Mr. Roby Bevam of your staff.

s

/ \\'

Im en inspectica conducted hvember 20 and 21,1974, (report no.

50-289/74-34) the licensee was cited for violation of Section 4.1.1.A of Appendix B tech spees. The citation read (see enclosure 1):

i j

"Section 4.1.1.1... requires, in part, that fish sampled as part of the fish impinsament study be counted, weighed, and t

[

identified to the p t feasible taxon."

x

" Contrary to this requirement, the total weight of all fish from each identified taxon was determined, rather than the individual fish weights."

i The licensee replied to that citation in a letter dated January 20, 1975, (see,ancinsure 2) with the statement:

4

[

1*The... Techate=1 Specification for impingement of fish at j

the ' unit intake structure requires counting, wMghing, and identification to the lowest feasible taxon. The program i

conducted by Met-Ed and our consultant meets the intent of this technfral specification."

"The consultant's procedure for weighing impinged fishes has j

been to w M gh all whola species together to the accuracy of

(

0.1 g.

This procedure was determined to meet the intent of the technical specification as a result of the professional judgment of the parties involved. If larger specimens had been observed, a subsample program would have been initiated."

"As water weight is an appreciable portion of the weight of m il fish, the additional Sand 14=* required to weigh indi-vidual fish could increase the chance for variation."

E9401o 79r7

e

-a

~

c

- e.

. W. H. Regan "The lengths of individual fish are taken, therefore the size of impinged fish can be determined from the length / frequency and intervals."

The Regional Office regarded the licensee's reply to this citation to be inadequate and forwarded it to Headquarters for action (see (Tht.c is, they thought the licensee should be weighing enclosure 3).

This was done because in our discussions with the individual fish.)

cognizant Environmental Project Manager, he agreed with the Regional Office interpretation of the tech spec.

Having established the understanding with Licensing Environmental Frejects that our interpretation of the tech was correct, werec licensee which af firmed the Regional Office citation and required the licensee to reply to Headquarters (see enclosure 4).

In our normal procedure for processing this Headquarters enforce-ment action, we staffed the enforcement letter through the Office 6

In that process of the Executive Legal Director for concurrence.

the ELD staff (Jim Murray) read the tach spec and disagreed with j

the interpretation given by the Regional Office in the citation l

(and agreed with by IE and the Licensing Environmental Projecta 6

Manager).

This memorandtna is to point out that, with the OELD interpretation, i

we are, at this time, acceptigg the licensee's present fish sampling I

and counting methods to be adequate for meeting the requirement of Techaie=1 Specification 4.1.1.A.

Futura inspections against this tech spec - as it's currently written - will be conducted accordingly.

f He informed me that he I discussed this subject with Roby Bevan.

i had contacted Sandy Lawyer of the Met Ed staff on March 5,1975, l

and that action had been initiated to revise and clarify Appendix On the basis of my discussion B Technical Specification 4.1.1.A.

with Bevas, and the understanding that action has been initiated H ad that we close our to revise the tech spec, I have r-e-enforcement correspondence and tell the licensee we plan to take no further action at this time (enclosure 5).

i i

4 U

-e-

~

-n,s,_a...

4 P-R 4

.e

-s c

W. H. Regan Please contact me if you have any questions about this memorandum By copy of this n.amorandum I'm asking Roby Bevan to contact me if I have incorrectly sev=narized our discussion of the subject.

I obtained his concurrence in the draf t enforcement letter (enclosure

4) by telephone and he is on distribution.

n C-e Leo 3. Higginbotham, Acting Chief Eadiological and Environmental Protection tranch Office of Inspection and Enforcament a

w 4

itncinsures:

, 1 1.

Ler: P.L Nelson to R.C. Arnold, dtd 12/20/74 2.

Ltr: W.E Creits to P.R. Nelson, dtd 1/20/75 t

3.

Ltz: P.R. Nelson to H.D. Thornburg, dtd 2/10/75 4.

Ltrt(draft): J.C. Davis to R.C. Arnold, undated j

5.

Ler (draft): J.C. Davis to 1.C. Arnolde y

undated, r

cc:

D. R. Mn11er DRL EF (w/ encl.)

R. Bevan, DRL EF (w/ encl.)

l J. G. Davis E. D. Thornburg l

E P. Ellia i

C. W. Ynh1 m B. L Weiss P. R. Nelson (F18043E2) i g

\\

[

o,,ic=

• mt, sw.mame

• _LB g4 nha t-F am nr 4/g

/75 Forze A.EC 318 (Rav. 9 53) AZCM 0240 W u. s. oovannucNT perintime orricas t e?..eas-see

n s v s. s. t

l. i i t. H G Y C C '.' *, i CN

((.

. ji., {f',p s.

pe,a u ons.it. ne n e. c. u i <. i

< s.. i.o n s

,,m.....

J.,1 03 % P Ann Av tt.UC

^

.9 KING oF PRU55t A, Fr.ntJ:.y t.vr.ru A 104tG h

F

1. rens (5 DEC 2 0W4 Hetropolitan Edison Company License !!o. DPR-50 Attention: lir. R. C. Arnold Inspection :o. 50-2S9/74-:'.

Vice President P.O. Box 542 Reading, Pennsylvania 19603 Gentlu:'.cn :

This refers to the inspection conducted by Mr. Borcs of this office on !!ovember 20 and 21, 1974 at Three Mile Island Nuclear Station of activitics authoriacd by AEC License No.

DPR-50 and to the discus; ions of our findings held by Ifr.

Borcs with ::r.11erbein and other acabers of your staff at the conclusion of the inspection, and to a subscquent telephone discussion betueen ir. Bores of. this office and !!r. lierbein j:

on November 25, 1974.

f Arcas examined during this inspection are described in the Regulatory j

Operations Inspection Report uhich is cnclosed with this letter.

'I Within these areas, the inspection consisted of selective exaninations

a of pror edures end reprecentative records, int

. ele..

Jith persc.'....l.

and ch.wv.T tirr.2 jh insp;;;.cr.

Our inspector also verified the steps you had taken to correct the violations brought to your attention in letters dated March 29, 1974 and June 26, 1974, follouing our inrp2ctions.

We have no further questions regarding these matters.

During this inspection, it uns found that certain of your activitics appeared to be in violation of AEC requirc=cnts.

The items and references to the portincat rcquirements are listed in the enclosure to this let,ter.

This letter constitutes a notice cent to you pur::uant to the provisions of Section 2.201 of the AEC's " Rules of Practic.", Part 2 Titic 10,. Code of Federal Regulations.

Section 2.201 requires you to submit to this office uithin 20 days of your rcccipt of this notice, a uritten statencnt of explanation in reply, including: (1) corrective steps uhich have been or will J

9 41.$120 7 4,

... ~..

..__..7.--

}!ctropo)it m Edison Company be taken by you, and the results achieved; (2) corrective steps which uill be taken to avoid further violations; and (3) the date when full cc pliance vill be ach cved.

Iloucver, uith regard to Items No. 1, 2 and 3, uc note that these violations ucre corrected prior to the ce=pletion of our inspection and therefore, no response eith respect to these matters is required.

In accordance with Section 2.790 of the AEC's " Rules of Practice",

Part 2, Titic 10, Ccde of rederal Regulations, a copy of this letter and the enclosed inspcetion report vill be placed in the AEC's Public Documant Roca.

If this report contains any information that you (or your contractor) belicyc to be proprictary, it is necessary that you make a uritten application uithin 20 days to this office to withhold such information from public disclosure.

Any such application cust include a full statement of the reasons on the basis of which it is claimed that the informatior is proprietary, and should be prepared so that proprietary

$nformation identified in the applicatica is contained in a

{

separate part of the document.

If uc do not hear fror you in j

this regard eithin the specified period, the report vill be placed in the Public Docu= cut Recc.

i Shculd you havc. ar.y questivu: cvacernin;.; chis inspection, uc will be pleased to discuss them uith you.

Sincerely, j pf U./rn

~

Paul R. Nelson, Chief Radiological and Environmental Protection Branch

Enclosures:

1.

Description of Violations 2.

R0 Inspection Report no. 50-289/74-34 cc:

J. C.11erbein, Station Superintendent R. W. IIcuard, Project '!anager, CPUSC h

.o.

i

~

I i

e j

_ENCLOSURI DESCRTPTIO'; 0F VIOI.ATIO::S y,.;topolitan Edison Company

..'. Box 542

uting, Pennsylvania 19603

,.eket Na. 50-289 Jertain activitics under your licence appear' to be in violation of AIC

e.;uiremen ts.

These violations have been reported to the AEC as

..vironmental Incidents and follou up action has been taken by the These apparent violations are considered to be of Category itecusec.

li severity.

1.

Section 2.1(a) of the Appendix B, Technical Specifications for Three s

Mile Island - Unit i limits the discharge vater temperature to no greater than 3*F below the inlet water temperature.

Cont:ary to this requirement, the discharge water temperature exceeded 3*F belou the inlet unter temperature on July 11, 15, 17 and 19, 1974.

(EI 74-8, Letter to Regulatory July 24, 1974).

I 2.

5:ction 2.2.la of th* Appendi 3, Tuchaien1 Specliscation limit.s em free ch?crfr.e _empr ant, a0 =casured at the river discharge, to less than 0.1 ppa.

Contrary to this requirement, the free chlorine component, as measured at the river discharge, equalled 0.1 ppa on September 26, 1974.

(El 74-9, Letter to Regulatory October 3, 1974).

3.

Section 2.2.3 of the Appendix B, Technical Spc~cifications requires.

that pil, as measured at the Waste Neutralizing Tank prior tc release, be between 6.0 and 9.0.

~

Contrary to these requirements, the pil. of material released from the Waste Neutralizing Tank exceeded these limits on August 31, September 15, 20 and 23, 1974.

(EI 74-10, Letter to Regulatory October 4, 1974).

Uc note that these matters ucre reported to Regulatory as indicated above.

Ycur corrective measures were reviewed during this inspection.

Uc have no further questions on these matters at this time.

't -7mpur 9 %

o 8

ee%

e.=

i 2

1 Certain activitics under your license appear to be in vinlation of AEC requircaents.

These apparent violations are considered to be of Cat III severity.

4.

Section 4.1.1.A of the Appendi:

that fish sampled as part of the fish impin~,cmentB, L

in part, counted, tecighed and identificd to the loucst c:udy be feasible taxon.

Contrary to this requirement, identified taxon uns dater =ined, rather than the individu s ucich 5.

Section 4.4c and Tabic 3 of Appendix B, Technical Specifications' in part, and uith sufficient sensitivity such that 0.5 pic equi j

of milk can be deternined at the time of sanpling uithin an overall e

analytical error of :25% at the one sigma confidence level.

Contrary to these require =cnts, in several instances the analys nnalysis was not sufficient to determine 0.5 pic a

I-131 in milk uithin :25'; overall analytical error.

l t

e e

9 e

e t.

e 9

9 e

e e

O ea. e asem.=

.gp M h 6 6 88'*"

'~L..

s' ;.:

r. :s t

~..

~.,.,..,.;,,

J:'OLlTAN EDISON CO,'.; PAN.V i.in

., =,

_..__..__...._.._.,m.___.-._._..

y, s t..t?

READING. PCtmSYLVArs!A 15~,03 TELEPHONE 215 - 9:D::c.1 JAN 2 01975 Janut.ry 20, 1975

}!r. Paul R. Nelson, Chief Radiological and Environmental Protection Branch Directorate of Regulatory Operations, Region 1 U. S. Atoraic Energy Commission 631 Park Avenue King of Prussia, Pennsylvania 19406 Daar lir. Meleen:

Docket No. 50-289 Operating License ro. DPR-50 Inspection Report 74-34 This letter and the attached enclosure arc in response to your inspection report letter of-December 31, 1974, concerning Mr. Bores inspection of our Three Mile Island Nuclear Station Unic 1 and the resultant findings of that inspcction.

i Sincerely,

-zuo.q W. M. Crof'tiz a

President WMC:RSB :tas Enclosure :

Response to Descrip ion we File : 20.1.i / 7.7.3.2.1 DUPLICATE DOCUMENT Entire document previously entered into system under:

ANO No. of pa.jes:

h

~

fJUCLEAR REGULATORY CCF 1SSION ntatou l 631 PAnK AVENUC KING OF PRUSSIA. PENNSYLVANI A 19406 FEB 10 6/5 H. D. Thornburg, Chief, Field Support and Enforcement Branch Office of Inspection and Enforcement, ilQ RO INSPECTIO:i REPORT NO. 50-289/74-34 (TIIREE MILE ISLAND UNIT 1)

INADEQUATE LICENSEE RESP 0::SE (TRACK ITEM F13043110)

The enclosed package is forwarded for action.

Item No. 4 of the enclosed licensee's reponse is not adequate as con-cerns meeting the requirements of his Technical Specifications.

Conence was cade with licensee management (Mr.

R. C. Arnold, Vice President) to attempt to resolve this matter.

At this time the licensee stated that although the NRC:RL Project Manager (Mr. D. Jaffe) verbally gave the licensee the same interpretation of this requirement as our inspector, i

TML would require a written interpretation of this requirement from RL i

before taking further action.

1 i

• l This matter is therefore forwarded for resolution.

t i!

/s./ b V Paul R. Nelson, Chief Radiological and Environmental Protection Branch

Enclosures:

l.

RO:I Letter to Licensee, dated December 20, 1974 2.

Licensee reply to RO:I, dated January 20, 1975 3.

RO:I Acknowledgement Letter to Licensee 4.

RO:I Note to File with Details of Telephone Contacts cc-C. Kuhlman F. Dreher i

h

+ p.-

mc 6 &Y Y))5 R&B ye a>WM

>>>.,e

~~

N UC t.C A R REGULM on Y CO?".',15' ION J

necto.y i G 3I PAR K f.VEN UI.-

KING OF PRU558 A, l'F.f!NLYLVAfdl A l'J 4 0 G FEP '

B75 Metropolitan Edinon Company License No. DPR-50 Attention:

Mr. R. C. Arnold Inspection Po. 50-2S9/74-34 Vice President P.O. Box 542 Reading, Pennsylvania

Reference:

Your letter dated January 20, 1974 In response to our letter dated December 20, 1974 Centlemen:

Thank you for informing us of the corrective and preventive actions i,

you docu: ented in response to our correspondcace.

These actions will be exaulned during a subscquent inspection of your license'd program.

With respect to Item 4. your response is not considered adequate in that 4

j, your described program does not appear to acet the requirements of this Technical 0;)ccification. As discussed in the telephone. conversation between I'r. Erunner of this offica and Mr. Arnold on.Tanuary 31, 1975, this iten han been sent te tha Office. of Inspecticn :nd Enforcencnt, NRC lleadquarters, for resolution.

Sincercly,

'~?

Gj,./ e./) *f,.,,. 6~ m,

a Paul R. Nelson, Chief Radiological and Environnental Protection Branch s

J. G. I!crboin, Station Superintendent cc:

R. W. Ilcward, Project Manager, GPUSC dq urt'.e,'i.

DUPLICATE DOCUMENT Entire document previouslY g.

e 5 h. J' e

entered into system under:

\\,$,:).!

ggo t(.

No. of Pages: U

~ - - - -..

_