ML19330A828
| ML19330A828 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/21/1980 |
| From: | Herbein J METROPOLITAN EDISON CO. |
| To: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| TLL-340, NUDOCS 8007290617 | |
| Download: ML19330A828 (13) | |
Text
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Middletown. Pennsytvania 17057 Post Of fice Box 480
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717 944 4041 Writer's Direct Dial Number July 21,1980 TLL 340 Office of Inspection and Enforcement Attn:
V. Stello, Director U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Decr Sir:
Three Mile Island Nuclecr Station, Unit I (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Responses to Items of Non Compliance On October 25, 1980, the NRC transmitted a Notice of Violation and a Notice of Proposed Imposition of Civil Penalties in the amount of $155,000. On December 15, 1980 Metropolitan Edison Company responded to these notices and received a response from the NRC on January 23, 1980 addressing both j
units. On March 6, 1980 a meeting was held between members of the NRC l
Inspection and Enforcement Region I office and those of Metropolitan Edison Company. At this meeting it was agreed that a final submittal would be sent for Unit II (May 19, 1980) and that corrective action for Unit I would be completed on a schedule commensurate with the restart of TMI-I.
To this end, enclosed please find the response for TMI-I.
Sincerely, Signed J. G. Herbein
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J. C. Herbein Vice President TMI-I JGH:LWH: hah cc:
J. T. Collins
- 3. J. Snyder B. H. Grier 1
H. Silver
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8 0 0 7 2 9 0 6/f uetrocotlan Edison company is a Memner of the General Pubhc Utrhtres System
TMI-I BCC LIST Mrs. Pat Higgins Mr. S. H. Duerson Edison Electric Institute Babcock & Wilcox 1111 19th Street, NW P.O. Box 1260 Washington, D.C.
20555 Lynchburg, VA 24505 Mr. E. L. Blake, Jr.
Mr. T. F. Hartley, Jr.
Shaw, Pittman, Potts & Trowbridge Marsh & McLennan, Inc.
1800 "M" Street, NW 1221 Avenue of the Americas Washington, D.C.
20555 New York, NY 10020 Mr. R. Sancore Ms. Margaret Reilly American Nuclear Insurers Chief Div. of Reactor Review The Exchange - Suite 245 PA Department of Environmental Resources 270 Farmington Avenue Fulton Bank Building
- Farmington, CT 06032 Harrisburg, PA 17120 E:$2ENII5"$?li'!n*f%"*"d"'*"
R. J. Toole - TMI-I Supervisor G. J. Troffer - TMI Trir. 198 R. F. Wilson - TMI Trir. 105 C. K. Hovey - TMI Trlr. 105 W. N. Moreau - Met-Ed Reading P. Clark - GPUSC Parsippany C. W. Smyth - Parsippany Licensing R. Fenti - TMI - QA Trir. 22 E. G. Wallace - Parsippany Licensing M. J. Ross - TMI - Ops. #1 W. E. Potts - TMI - Radiation Control - 1 L. W. Harding - TMI Licensing A. Bell l-TMI GORB Secretary - Parsip.
R. M. Klingaman - Met-Ed Reading M. Nelson - Trl. 60 N. Kazanas - Parsippany - QA M. A. Shatto - TMI-I PORC Secretary - Eng. #1 J. F. Wilson - TMI Trir. 14 G. A. Kunder - TMI-II PORC Chairman - Trl. 104 J. J. Colitz - TiiI-I W. F. Schmauss - TMI-I GRC Chairman - Parsip.
B. Ballard - TMI Trir. 16 J. Thiesing - Bechtel Room #201 Admin Bldg.
G. P. Miller - TMI-I P. S. Walsh - CPU Parsippany R. C. Arnold - TMI - Trir. 201 D. Smith - Reading - Production Supervision D. G. Mitchell - Met-Ed Reading J. T. Collins - NRC Trlr. #1 L k n, c f-Tra ; n f n p- /na a 9.c r-R. A. Lengel - Engineers #1 File:
02.0016.0001.0001.02 40
.e ITEM 1 Provide a supplemental response which specifies (1) each procedure reviewed for TMI-I which isolates or defeats part or all of any system w:7se operation is required by the Technical' Specifications or by the accident analysis contained in the FSAR; and (2) the cathod by which the operability requirements will be
-satisfied during the conduct of each procedure in (1).
RESPONSE 1 TMI-I procedures have undergone extensive review and revision. Four admin-istrative procedures; AP 1001 Document Control AP 1002 Switching and Tagging AP 1016 Operations Surveillance Program AP 1010 Technical Specification Surveillance Program are being revised to ensure redundant loops containing safety related equipment are not inoperable and that equipment is properly returned to service following surveillance or maintenance (see also Section 2 of the TMI-I Restart Report). Revisions to operating, surveillance and maintenance procedures to incorporate NRC requirements and TMI-I Restart Report commitments are substantially complete with regard to equipment operability.
A management policy statement regarding compliance with operating and maintenance procedures and instructions to applicable personnel has been issued.
In addition, training programs have been initiated that stress equipment operability and the importance of procedural-compliance as described in Section 6 of the TMI-I Restart Report.
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-ITEM 2 Provide a supplemental response concerning the radiological controls program specifying (1) the corrective steps which have been taken and results achieved; (2) corrective steps which will be taken to avoid further items of non compliance; and (3) the date when full compliance will be achieved.
RESPONSE 2 The revised TMI-I Radiation Protection Plan is included in Section 7 of the TMI-I Restart Report.
M t-Ed is in the process of thoroughly reviewing and e
appropriately revising the approximately 60 Health Physics procedures, and currently projects all procedures to be finalized, approved and in effect by September 1, 1980. The TMI-I Restart Report, Sections 4, 6, and 7 discuss Onsite Radiation Protection Equipment, Training and Radiation Protection respectively.
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t ITEM 3 Provide a supplemental response concerning the actions to be taken to assure Plant Operations Review Committee (PORC) members have the necessary technical expertise to demonstrate clear understanding of the Technical Specifications (TS) requirements and system operability requirements as stated in the TS and FSAR.
RESPONSE 3 TM1-I organization, including onsite and offsite review functions and review group composition are currently under review by Met-Ed.
An amendment to Section 5 of the THI-I Restart Report, scheduled for submission by August 1, 1980, will address the membership and responsibilities of these onsite and offsite groups, including PORC. A proposed Technical Specification Change will be submitted subsequent to the Restart Report Amendment reflecting all organizational changes.
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1 Tim 4 A.
Provide in a supplemental responso those steps being taken to assure that changed plant operating conditions will be factored promptly into emergency and operating procedures to assure that such procedures remain appropriate for staff use.
Additionally, the actions required upon identification of symptoms should be included in this response.
B.
Provido those measures taken to insure that operability requircuents of the Engineered Safety Features are met during all phases of operation.
C.
Provide the actions to be taken, including procedural improvements, to establish the required steam generator water level in all modes of feedwater or emergency feedwater addition.
4 D.
Provide the date of full compliance in regards to AP 1004 TMI Emergency Plan.
I RESPONSE 4
't TMI-I proceduras have undergone extensive revlew and revision. Four administrative procedures; l
AP 1001 Document Control AP 1002 Switching and Tagginn AP 1016 Operations Surveillance Program AP 1010 Technical Specification Surveillance Program have or are being revised to ensure redundant loops of safety related equipment a
I are not inoperable and that equipment is property returned to service followinn surveillance or maintenance (sce also TMI-I Restart Report, Section 2).
Revisions to operating, surveillance and maintenance procedures to incorporate NRC require-ments and Restart Report commitments are substantially complete with regard to equipment operability.
A management policy statement regarding compliance with Operation and Maintenance I
procedures and instructions to applicable personnel, has been issued. As noted in Met-Ed's response of May 19, 1980, a series of meetings were conducted with operations personnel to address the need to comply with procedures and personnel responsibilities for identifying when procedures require revision.
In addition, training programs have been initiated that stress equipment operability and the importance of procedural compliance as described in the TMI-I Restart Kcport, Section 6.
~ Revision 2 of TMI Unit I Emergency Plan was submitted to NRC for review on June 10, 1980. Approximately 35 Emergency Plan Implementing Procedures (EPIP) consistent with Revision 2, are currently under preparation, revision, or internal review. All EPIP's will receive review by the PORC and the unit manager prior to finalization. Met-Ed estimates that the Epip's will be finalized by September 1, 1980.
ITEM 5 Provide a supplemental response concerning the review and approval of procedurcs impicmenting the Emergency Plan.
RESPONSE 5 Revision 2 of TMI-I Emergency Plan was submitted to NRC for review in early. lune, 1980.
Approximately 35 Emergency Plan Impicmenting Procedures, consistent with Revision 2, are currently under preparation, revision or internal review. All Emergency Plan d
Impicmenting Procedures will receive review by the PORC and the Unit Superintendent (or their successors) prior to finalizatlon. Met-Ed estimates that the Emergency Plan Impicmenting Procedures will be (Jnalixeit by September 1, 1980.
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- o ITEM 6 Provide a ' supplemental response addressing the calibration of environmental air samplers.
RESPONSE 6 Met-Ed's response to this '. tem for TMI-II dated May 19, 1980, identified corrective action taken relative to offsite continuous air samplers.
This response is also applicable to Unit I.
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ITEM 7 Provide a supplemental response addressing the onsite and offsite organization.
RESPONSE 7 Onsite and offsite organi::ation are currently addressed in Section 5 of the TMI-I Restart Report which is scheduled for revision by August 1, 1980. A proposed Technica1' Specification change will be submitted subsecuent to the TMI-I Restart Report amendment reflecting all organizational changes.
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l ITDI 8 Provide a supplemental response addressing the retraining and replacement training program for the unit staff which meets the requirements of ANSI N 18.1-1971.
RESPONSE 8 The response to Item 8 of the May 19, 1980 letter also applies to TMI-I (See TMI-I Restart Report Section 6).
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ITEM 9 Provide a supplemental response addressing Reactor Coolant System Leakage.
RESPONSE 9 TMI-I Procedure 1303-1.1 identifies actions to be taken in the event unidentified Reactor Coolant System Leakage exceeds technical specification limits of one (1) gallon per minute (CPM). A revision incorporating TMI-II lessons learned has been submitted and is currently being reviewed. This review is expected to be completed by November 1, 1980.
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ITEM 10 Provide a supplemental response addressing records of surveys, radiation monitoring and disposal retention.
RESPONSE 10 The response to Item 10 of t'.e May 19, 1980 letter also applies to TMI-I.
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ITEM 11 Provide a supplemental response addressing the specific requirements and methods of implementing these requirements concerning the inspection of activities affecting quality as they are performed.
RESPONSE 11 The response to Item 11 of the May 19, 1980 letter also applies to TMI-I Revision 8
- to the Operational Quality Assurance Plan is contained in the TMI-I Restart Report Supplement 2.
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