ML19308B477
| ML19308B477 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/11/1978 |
| From: | Herbein J Metropolitan Edison Co |
| To: | Grier B NRC Office of Inspection & Enforcement (IE Region I) |
| Shared Package | |
| ML19308B473 | List: |
| References | |
| NUDOCS 8001030252 | |
| Download: ML19308B477 (3) | |
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METROPOLITAN EDISON COMPANY suasioianyorceneau pueucununesconponarion POST OFFICE BOX 542 READING, PENNSYLVANI A 19603 TELEPHONE 215 - 929 3601 December 11, 1978 GQL 1988 Mr. B. H. Grier, Director Office of Inspection and Enforcement Region 1 U. S. Nuclear Regulatory Cc= mission 631 Park Avenue King of Prussia, Pennsylvania 19h06 D:ar Sir:
Three Mile Island Nuclear Station, Units 1 & 2 ('IMI-1 & TMI-2)
Operating License Nos. DPR-50 and DPR-73 Docket Nos. 50-289 and 50-320 Inspection Report Nos. 78-18 & 78-31 This letter and the attachment are in response to your inspection findings letter of November 21, 1978, concerning Mr. Plumlee's inspection of TMI-1 and TMI-2.
Results indicate.d one apparent deficiency for TMI-1 and two ap-parent infractions for TMI-2.
Sincerely,
^
J. G. Herbein Vice President-Generation JGH:JRS:cjg Attachment N
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oA Metropolitan Edison Company 2
Please respond to this office within seven (7) days of receipt of this letter a written statement containing the above evaluation.
Sincerely, Ge ge
. Smith, Chief Fu 1 Facility and Materials Safety
$ ranch CC*
E. G. Wallace, Licensing Manager J. J. Barton, Project Manager R. C. Arnold, Vice President - Generation L. L. Lawyer, Manager - Generation Operations - Nuclear G. P. Miller, Superintendent J. L. Seelinger, Unit 1 Superintendent J. B. Logan, Unit 2 Superintendent G. A. Kunder, Unit 2 Superintendent - Technical Support I. R. Finfrock, Jr.
Mr. R. Conrad G. F. Trowbridge, Esquire Miss Mary V. Southard, Chairman, Citizens for a Safe Environment i
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Attachm:nt GQL 1988 M;tropolitan Edison Company Three Mile Island Nuclear Station License Nos. DPR-50/LPR-73 Docket Nos. 50-289/50-320 Inspection Nos. 78-18 (TMI-1)/78-31 (TMI-2)
Based. on the results of an NRC inspection conducted on October 6, 10-12, and 17-19, 1978, it appears that certain of your activities were not conducted in full compliance with NRC regulations and the conditions of your license as indicated below.
Items A and B are infractions and item C is a deficiency.
Infraction A:
Technical Specifications Section 6.13.1 requires that each high radiation area (100 mrem /hr or greater) be barricaded and conspicuously posted as a high rad-iation area.
Contrary to this requirement, at 3:00 p.m., on October 6, 1978, there was neither a barricade nor a conspicuously posted high radiation area sign at an unattended high radiation area located in the Unit 2 reactor coolant drain tank room wherein the radiation level was measured at up to 180 mr/hr 12 inches from some 55 gallon druns of reactor orifice rods stored in this rocm.
Response to Infraction A:
The area had previously been barricaded, locked and properly posted; however, the barricade, which consisted of a wooden door fraae, ja--ed into the opening with shims, and a wooden door, had fallen due to expansion and contraction during thermal cycles within the reactor building.
Therefore, a gate type door has been installed which has a frame bolted to the opening of the drain tank room.
The door is locked and has the proper posting and barricading of areas was discussed at a department meeting with the H.P.
Technical Staff held on 12-1-78.
Full compliance was achieved on October 7,1978.
Infraction B:
10 CFR 20.201(b), " Surveys," requires each licensee to make or cause to be made such surveys as may be necessary for him to comply with the regulations in this part.
Contrary to this requirement, a timely survey was not conducted as was necessary to identify and post a radiation area in the Unit 2 makeup pump room 1-C to comply with the requirements of 10 CFR 20.303(b), " Caution signs, labels, signals, and controls." The radiation dose rate was measured at 10 mr/hr at 12 inches frcm decay heat removal system piping in this unattended non-posted area at 3:20 p.m., on October 6,1978.
Response to Infraction B:
The area was surveyed and properly posted shortly after the inspection. Full
o compliance was achieved on October 6, 1978. To prevent recurrence, the H.P.
Foreman has spoken to the Unit II Operations Supervisor to stress the impor-tance of ccm=unication between the two departments when plant changes occur which may alter radiation levels.
Scheduling of the surveying of the makeup pump 1-C room is on a computer program to ensure that it is performed on a frequent basis.
Dnficiency C:
Environmental Technical Specificatione Section 2.C reqpires that sampling and analyses of radioactive effluent releases through the auxiliary and fuel handling building exhaust vent and the reactor building purge vent release points be recorded,and the errors associated with each sample analysis be retained.
Contrary to the above requirements, the sample flow rate readings and the sampling times used in calculating the Unit 1 vent sample volumes prior to September 1978, had been discarded and any errors in calculating the sample volumes could not be evaluated. As a conseqpence, potential errors of the order of 10% of the monthly gaseous releases could not be evaluated.
Response to Deficiency C:
It is the opinion of the Met-Ed Staff that the sampling and analysis of radioactive effluent releases through the auxiliary and fuel handling exhaust vent and the reactor building purge vent release points is conducted in full compliance with the requirements of the Technical Specifications.
It is as-sumed that the reference to Environmental Technical Specification Section 2.C is in fact Section 2.3.2.C which states:
" Facility rzaords of iodine and particulate releases with half-lives greater than eight days shall be main-tained.
The error associated with each sample analysis shall be retained.
Records shall be maintained and reports of the sampling and analysis results shall be submitted in accordance with Section 5.6.1 of these specifications.
Estimates of the error associated with each reported value should be included."
Facility records of releases consisting of sample volume, sample analysis and analysis error are maintained.
Although the sample flow rate is not maintained, it can be calculated from the sample time which can be retrieved and the sample volume.
Each analysis centains an error consistant with the provisions of Regulatory Guide 1.21 paragraph 11.a.
Reports have been and will continue to be submitted in accordance with Technical Specification Section 5.6.1, which requires that reports be submitted in accordance with Regulatory Guide 1.21.
Errors on values reported are compiled as specified in paragraph 11.a of Reg-ulatory Guide 1.21 and submitted as part of the report. As a result the "...
potential errors of the order of 10%..." are assumed to exist as allowed by Regulatory Guide 1.21 and are reported as such.
Therefore, the Met-Ed Staff believes that no item of noncompliance exists.
However, to ensure that com-plete data is available, without retrieval, sample time and flow rate vill be recorded in the future.
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