ML19330B713
| ML19330B713 | |
| 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 8008050411 | |
| Download: ML19330B713 (13) | |
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Middletown. Pennsylvania 17057 Post Office Box 480 717 944 4041 wnter's Direct Dial Numoer July 21,1980 TLL 340 Office'of Inspection and Enforcement Aten:
V. Stallo, Director U. S. Nuclear Regulatory Commission tJashington, D.C.
20555
Dear Sir:
Three Mile Island Nuclear Station, Unic I (TMI-1)
Operating License No. DPR-50 Docket No. 50-239 Responses to Items of Non Compliance on October 25, 1980, the NRC transmitted a Notice of Violation ar.d a Notice of Proposed Imposition _of Civil Penalties in the amount of $155,000. On December 15, 1980 Metropolitan Edison Company responded to these notices and received a response from the NRC on January 23, 1980 addressing both units. On March 6, 1980 a meeting was held between members of the NRC Inspection and Enforcement Region I office and those of Metropolitan Edison Company. At this meeting it was agreed that a final submittal would be sent for Unit II-(May 19, 1980) and that corrective action for Unit I would be completed ori a schedule coc:=ensurats with the restart of UtI-1.
To this end, enclosed please find the response for TMI-I.
Sincerely, S;gned J. G. Herbein J. G. Herbein Vice President D1I-I JCH:LL'H: hah cc:
J. T. Collins B. J. Snyder
- 3. H. Grier H. Silver R. 11 Reid D. Dilanni THIS DOCUMENT CONTAINS 5
P0OR QUAUTY PAGES
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80'08050
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!!rs. Pat Higrins Mr. S. H. Duerson Edison Electric Institute Babcock & Wilcox 1111 19th Street, h".?
P.O. Box 1260 Washington, D.C.
20555 Lynchburg, VA 24505 Mr. E. L. Blake, Jr.
Mr. T. F. Har: ley, Jr.
Shaw, P1 : man, Potts & Trowbridge Marsh 6 McLennan, Inc.
1800 "M" Street, IN 1221 Avenue of the A=cricas Washington, D.C.
20555 New York, NY 10020 Mr. R. Sancore Ms. Margaret Reilly American ::uclear Insurers Chief Div. of Reactor Review The Exchange - Suite 245 PA Department of Environmental Resources
- 270 Farmington Avenue Fulton Bank Building Farming:en, CT 06022 Harrisburg, PA 17120 MEeENch B. A. Hockley - Diacover" Rocm Crawford Static bNitditeddh;&$Nh S. D{ Chaplin - DII Licensing R. J. Toole - Oil-I Supervisor G. J. Troffer
'"MI Trir. 198 R. F. Wilson - 21I Trir. 105 G. K. Hovey - DiI Trir. 105 W. N. Moreau - Met-Ed Reading P. Clarh - CPUSC Parsippany C. W. Smy:h - 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
- 21I GORB Secretary - Parsip.
R. M. Klingaman - Me:-Ed Racding M. Nelson - Trl. 60 N. Kazanas - Parsippany - QA M. A. Shatto - D!I-I PORC Secretary - Eng. #1 J. F. Wilson - O!! Trir. 14 G. A. Kurder - TMI-II PORC Chairman - Trl. 10 J. J. Coli:: - TMI-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 - GPU Parsippany R. C. Arnold - TMI - Trir. 201 D. Smi:h - Reading - Production Supervision D. G. Mitchell - Met-Ed Reading J. T. Collins - NRC Trir. 01
'A. kn,c.f-Tra. avis. hw a cer.
R. A. Lengel - Engineers fl c
File: 02.0016.0001.0001.02 d
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' Provide-a supplemental response which' specifies (1) each ' procedure reviewed for TMI-I:which isolates or=defea:s part or all of any system whose operation is
. required by the Technical Specifications.or by the accident analysis contained in the FSAR; and (2). the method by which the operability requirements will be satisfied during the-conduct of each procedure in (1).
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RESPONSE 1 TMI-I procedures have undergone ex:ensive review and revision. Four admin-istrative procedures; A? 1001; Document Con:rol
.A? 1002. Switching and Tagging A? 1016. operations Surveillance Program AP 1010 Technical Specification Surveillance Program are being revised-to ensure redundant loops containing safety related equipment are"no: inoperable. and that equipment is properly returned to service following surveillancelor caintenance (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 :o' equipment operability.
A management policy s:atement.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
'Restar:. 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)1the date when full compliance will be achieved.
RESP 0NSE 2 The revised TMI-I Radiation ? otection Plan is included in Section 7 of the TMI-I Restart Report. Mec-Ed is in the process of thoroughly reviewing and 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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ITDI 3 Provide a supplemental response concerning the ac:1ons to be taken to. assure Operations. Review Committee (PORC) members have the necessary technical Plan:
expertise to demonstrate clear unders:anding of the Technical Specifications (TS).
requirements and system. operability requirements'as stated-in the TS and FSAR.
s RESFONSE 3 TMI-I organization,' including onsite and offsite review functions and review An amendment to Section group composition are currently under review by Met-Ed.
5 of the.TMI-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 submit:ed subsequent to the'Restar: Repor: Amendment reflecting all organiracional changes.
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tTEM 4 A.
provide in a supplemental responso those steps being taken to assure that changed plant operating conditions wLit 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.
Provide those measuret taken to insure that opurability requirements of the Enginee^ d 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.
D.
Provide the da'te of full compliance in regards to AP 1004 TMI Emergency Plan.
RESPONSE 4 1
TMI-I procedures have undergone extensive review and revision. Four administ rative procedures; AP 1001 Document Control AP 1002 Switching and Taggine.
AP 1016 Operations Surveillance Program AP 1010 Technical Specification Surveillance Program have or are being revised to ensure redundant loops of safety related equipment are not inoperable and that equipment is property returned to service following surveillance or maintenance (see also TMI-I Restart Report, Section 2).
Revisions to operating, surveillanca and maintenance procedures to incorporate NRC rc<piirc-ments and Restart Report commitmcats are substantially complete with regard to equip =cnt. operability.
A management policy statement regarding compliance with Operation and Maintenance 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 pro 3 rams have been initiated that stress equipment operability and the importance of procedural compliance as described in the TMI-I Restart Report, Section 6.
Revisicn 2 of TMI Unit I Emergency Plan was submitted to NRC for raview 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 finalisation. Met-Ed estimates that the EPip's will be finalised by September 1, 1980.
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s h EM 5 provido a supplemental response concerning the. review and approval of procedures
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impicmentinf the E=ers;ency Plan.
! ansPONSE ' 5_ '
Revision 2 of 'IMI-I Emergency Plan was submi t ted to NRC for review in early June,1980.
- Approximately_35 Emergency Plan Implementing Procedures, consistent with Revision 2, are currently under preparation, revision or -internal. review. All Emergency Plan.
Implementing-Procedures will receive review by the PORC and the Unit Superintendent
.tet-Ed cstimates that the bergency
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(or their successors) prior to finalization.
Plan. Implementing Procedures will be finnlizeit by September 1, 1980.
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I' SITEM'6' Provide a ' supplemental: response addressing the calibration'of environmental air
. samplers.-
RESPONSE 6 Met-Ed's response to this item 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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I'"Ev. 7 Provide ~a supplemental response addressing the onsite and offsite. organization.
RESPO!:SE 7 f the TMI-l
.Onsite and offsite organization are currently addressed in Section 5 o
-Restart. Report which is scheduled for revision by August 1, 1980. A proposed to the TMI-I Restart
. Technical Specification change will be'sub=itted subsequent Report amendment reflecting all organizational changes.
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-ITDi'8 Provide a supplemental response addressing the retraining and replacement training progract for the~ unit staff which meets the. requirements of ANSI N 18.1-1971.
RESPO:!SE 8' The response to Item'8 of the May19, 1980 letter also -applies to TMI-I- (See 7II-I
- Restart Report Section 6).
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- TE'! 9 Previde a. supplemental-response addressing Reactor Coolant System Leakage.
RESPOSSI 9-n!I-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 =inute (GPM). A-revision' incorporating n!I-II lessons learned has
-been submitted and is currently being reviewed. This review is expected to be
. comp eted_by November 1, 1980.
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- ITEM'10
. Provide'a: supplemental response addressing records of. surveys, radiation monitoring andfdisposal retention.
-RESPONSE 10-
'.The' response to Item 10 of the May 19, 1980 letter also applies to DiI-I.
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ITEM ll-
- Provide a supplemental response addressing.the' specific requirements and methods of i=clenenting these requirements concerning the inspection of activities
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affecting quality as they are performed.
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' 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 IKI-I Restart Report-Supplement 2.
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