ML19343B170
| ML19343B170 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/21/1980 |
| From: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Arnold R METROPOLITAN EDISON CO. |
| References | |
| NUDOCS 8012150025 | |
| Download: ML19343B170 (39) | |
See also: IR 05000320/1979010
Text
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UNITED STATES
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Docket No. 50-320
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Metropolitan Edison Company
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ATTN:
Mr. R. C. Arnold
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Senior Vice President
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100 Interpace Parkway
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Parsippany, New Jersey 07054
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Gentlemen:
Subject:
Investigation 50-320/79-10
This refers to your letter dated December 5,1979, in response to our letter
dated October 25, 1979 and to your additional letter dated May 19, 1980 in
response to our letter dated January 23, 1980.
Based on NRC staff review of your responses, we have determined that certain
corrective measures remained deficient due to lack of specificity and complete-
ness.
Several meetings and telephone discussions were conducted ~ subsequently
between members of your staff and the NRC Region I staff.
Additional commit-
ments made by your staff during these sessions, as described in Appendix A,
were confirmed during telephone discussions between Mr. J. M. Allan, Deputy
Director, Region I, and Mr. G. Hovey, Director, TMI-2, on November 6 and 20,
1980.
If our understandings of these commitments are incorrect, please advise
this office in writing within 20 days of receipt of this letter.
Your May 10. 1980 letter described several corrective actions to be taken for
the radiological controls and emergency preparedness programs for which the
committed dates for completion were not met.
During the various subsequent
meetings and discussions described above, the dates for corrective actions
were revised to as much as 3, 5 and 6 months past the original commitment
dates.
Failure to complete these corrective actions by the dates you had
originally specified is similar to the lack of prompt attention previously
given to correcting those weaknesses identified in the Metropolitan Edison
letter to NRC Region I dated July 18, 1979.
Failure to complete corrective
actions by the committed dates shown in Appendix A will not be accepted and
may result in enforcement action.
The corrective and preventive acticis documented in your letters dated December
5, 1979 and May 19, 1980 and in the enclosu e will be examined during subsequent
inspections of your licensed program.
8012150026
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Metropolitan Edison Company
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In accordance with Section 2.790 of the NRC's " Rules of Practice", Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and the enclosure
will be placed in the NRC's Public Document Room.
Sincerely,
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Victor St'ello, Jr.
Director
Office of Inspection
and Enforcement
Enclosure:
Appendix A
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Appendix A
For each item of noncompliance and associated Civil Penalty identified in the
Notice of Violation (dated October 25, 1979) the original item of noncompliance
and the Of' ice of Inspection and Enforcement's initial conclusion regarding
the licensee's response is restated. In addition, the licensee's supplemental
response of May 19, 1980, commitments made during various meetings and conversa-
tions held in September and October, 1980, and the Office of Inspection and
Enforcement final evaluation for each item, is presented, where applicable.
ITEM 1
Statement of Noncompliance
Technical Specification 3/ 4.7.1, " Turbine Cycle," requires in Section 3.7.1.2,
that three independent steam generator emergency feedwater pumps and associated
flow paths shall be operable during power operations, except:
if one emergency
feedwater system is 'noperable 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 Shutdown 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 paths to both
steam generators were made inoperable by feedwater header isolation valve
closure.
(In addition, on January 3, February 26 and March 26, 1979, the flow
paths from all three emergency feedwater pumps were simultaneously made inoper-
able by feedwater header isolation valve closure during the performance of,
and in accordance with, an improper surveillance test procedure.)
Conclusion of January 23, 1980
The item at stated is an item of noncompliance.
The information provided by
the licensee does not provide a basis for modification of the enforcement
action. In view of Metropolitan Edison's interpretation of TS 3/4.7.1 and of
our conclusions concerning this item, a supplemental response is requested
which specifies:
(1) each procedure reviewed for TMI-2 which isolates or
defeats part or all of any system whose operation is required by the TS 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
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identified in (1).
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Supplemental Response
In a letter dated May 19, 1980, the licensee, stated that a review of Recovery
Mode Surveillance procedures will be performed as requested by the NRC.
A
list of all the procedures reviewed will be provided along witt an explanation
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of problems found and the method by which component / system operability is
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assured when they are removed from service to perform the surveillance (i.e.,
instrument calibrations).
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Appendix A
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The target date for completion of this review was June 30, 1980.
During various conversations and meetings held in September and October 1980,
the licensee provideJ additional spccificity and/or commitments regarding
corrective actions for this noncompliarce as desuribed below.
As stated above, Surveillance Procedures related to activities which isolate
or defeat part or all of a system whose operation is required by the TS or by
accident analysis in the FSAR were performed (licensee letter TLL 331, dated
July 10, 1980).
AP-1002, Rules for the Protection of Employees Working on
Electrical and Mechanical Apparatus, Revision 20, requires that alternate
safety trains be verified operable prior to removing one from service and that
upon restoratian of a component / system to service that it would be verified
However, it was noted that the above referenced letter (TLL 331,
.
dated July 10, 1980) did not address the verification of redundant safety
train operability prior to removal from service.
Two other actions are being taken to review other procedures as well as surveil-
lance procedures related to such activities as an ongoing activity.
The first is that in PORC review of new or revised procadures, special attention
will be directed at this matter.
This action will be an important feature of
the PORC member training program.
The second is tnat in the periodic review of procedures, required by T.S.
6.8.2, this matter will also be emphasized.
All applicable procedures will be
reviewed by September 30, 1982.
This review will assure both that alternate
(redundant) safety trains will be verified operable prior to removing one from
service (not addressed for surveillance procedure per TLL 331 letter) and that
the one removen f*om service will be verified operable after the reason for
its removal from service is completed.
A report listing all procedures so
reviewed and the findings (and corrective action where appropriate) will be
submitted no later than October 31, 1982.
In addition, to assure proper
!
component lineups, a shift check-off list is 'oeing prepared.
At this time the
only items this list will include are those with direct safety relationship
considering the current status of the system.
In accord with ALARA principles,
some items may have to be omitted or checked infrequently.
In addition, a management policy statement regarding compliance with procedures
and instructions to applicable personnel was issued March 7, 1980.
This was
supplemented by management discussion of the matter directly with operating
personnel in April, 1980.
The licensee reported that this communication of
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management policy of face-to-face discussion wherein questions could ta asked
and answered was very effective.
Further, the licensee stated that the sincerity
of management on the subject was made abundantly clear.
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Appendix A
3
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This action is being supplemented by incorporation of tne thrust of the management
directive into a new procedure which will supplement Administrative Procedure
1001.
This new procedure was to be in place by November 17, 1980, and will be
implemented after a period appropriate for familiarization and learning.
This
procedure will give added guidance as to how this management directive is +-
be implemented.
While the prompt follow-up to this directive was directed at
operating people, the incorporation of this emphasis and its implementation
into the new procedure will communicate the strong management feeling to all
who use TMI-2 procedures.
Final Evaluation
The licensee's previous and additional corrective actions are acceptable.
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Appendix A
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ITEM 2
Statement of Noncompliance
The severity and uniqueness of the accident which occurred at Three Mile
Island resulted in a marked reduction in the normal good health physics practices
which are mandated by the NRC Regulations.
Under the circumstances of an
accident of'this magnitude, the NRC recognizes that in the interest of reactor
safety a departure from normal health physics practices and standards may
sometimes be mandated by the exigencies that exist during such conditions.
However, the NRC also believes thai ...e
licensee, with the resources available
and taking into account the time f rame available for conduct of safety-related
functions, could have taken additional measures to better control the over til
health physics actions and decisions which were made during the course of he
accident.
The following items of noncompliance exemplify unacceptable degradation
from health physics practices pertaining to control of access to high radiation
areas, conduct of radiation surveys, and personnel radiation exposure monitoring
10 CFR 20.201, " Surveys," requires in Section (b) that each licensee shall
make or cause to be made such surveys as may be necessary to comply with the
regulations in 10 CFR 20.
10 CFR 20.202, " Personnel Monitoring," requires that the licensee supply
appropriate personnel monitoring equipment and requires its use for each
individual who enters a restricted area and is likely to receive a dose in
excess of 25 percent of the applicable value specified in 10 CFR 20.101.
Technical Specification 6.12, "High Radiation Area," requires that each area
in which the intensity of radiation is greater than 1000 mrem /hr be provided
with locked doors to prevent unauthorized entry into the area and that any
individual enterirg the area be equipped with a continuously indicating dose
rate monitoring device.
10 CFR 20.103, " Exposure of individual's to c5ncentrations of radioactive
materials in air in restricted areas," requires in Section (a)(3) that the
licensee make suitable measurements of the concentrations of radioactive
mate-ials in air for detecting and evaluating airborne radioactivity in restricted
areas for the purposes of determining compliance with the regulation in 10 CFR 20.103(a)(1).
10 CFR 20.101, " Exposure of individuals to radiation in restricted areas,"
requires that no licensee possess, use or transfer licensed material in such a
manner as to cause any individual in a restricted area to receive in any
period of one calendar quarter a dose in excess of three rem to the whole
body, or 18 3/4 rem to the hands and forearms, or f7 rem to the skin of the
whole body.
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Appendix A
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Contrary to the above:
A.
From 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> on March 28, 1979, until the afternoon of March 30, 1979,
the doors to the auxiliary building were not locked and access was not
otherwise controlled even though the building was knuwn to be a high
radiation area with radiation levels much greater than 1000 mrem /hr
during this period;
8.
From the evening of March 28, 1979, until the evening of March 29, 1979,
at least two entries into the auxiliary building were made by individuals
who were not equipped with a radiation monitoring device which continuously
indicated the dose rate;
C.
No measurements were made of the concentrations of airborne radioactive
materials in the Unit 2 auxiliary bui.lding for periods during which
individuals :ere exposed from 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> on March 28, 1979, through
midnight, March 30, 1979, nor in the Unit 1 nuclear sample room and
primary chemistry laboratory for periods during which individuals were
exposed from 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> on March 28 through 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> on March 30, 1979;
D.
On March 29, 1979, an Auxiliary Operator was permitted to enter areas of
the auxiliary building where exposure rates of up to 100 R/hr existed.
Radiation survey information and appropriate personnel monitoring were
not provided to the operator for this entry.
This contributed to the
operator receiving a whole body dose of 3.170 rems.
When this dose was
added to the operator's previous dose for the quarter, the operator's
quarterly whole body dose was 3.870 rems as measured by personnel dosimetry
devices;
E.
On March 29, 1979, a Nuclear Engineer entered an area of the auxiliary
building where the radiation level was greater than that which could be
measured by his portable survey instrument (2 R/hr).
Failure to perform
a survey of the exposure rate in this area contributed to the individual
receiving a whole body dose of 3.14 rems * for this entry.
When this dose
was added to the engineer's previous dose for the quarter, the engineer's
quarterly whole body dose was 4.175 rems as measured by personnel dosimetry
devicts;
F.
On March 29, 1979, a Chemistry Foreman was permitted to repeatedly enter
high radiation areas and handle samples of highly radioactive reactor
coolant.
This contributed to the Foreman receiving a whole body dnse of
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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 ard a Radiation Protection Foreman
were permitted to handle a highly radioactive reactor coolant sample
without adequate personnel monitoriig and without first performing a
survey of hand and forearm exposure rates.
Handling of this sample
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Appendix A
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resulted in a calculated dose to the hands and forearms of the Chemistry
Foreman of about 147 rems and a ca'- '.ted dose to the hands and forearms
of the Radiation Protection Foremer
the range of 44 to 54 rems; and
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On March 28, and March 29, 1979, several individuals received skin con-
tamination of the hand and other parts of the body sufficient to cause
exposure rates in the range of 20-100 mR/hr when measured with a hand-held
survey instrument and no evaluation of the dose to the skin of thEte
individuals was made.
General Conclusion of January 23, 1980
The items as stated are items of noncompliance.
The information provided in .
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the licensee's response does not provide justification for withdrawing any of
the examples of noncompliance cited, nor does it provide justification for
remission or mitigation of the proposed penalty.
Commitments provided for
corrective action are incomplete as discussed.
A supplemental response is
requested which specifies in greater detail:
(1) the corrective steps which
have been taken and results achieved; (2) corrective steps which will be taken
to avoid further items of noncompliance; and, (3) the date when full compliance
will be achieved.
This supplemental information is requested f r each example-
listed.
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Appendix A
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ITEM 2.A
Specific Conclusion of January 23, 1980
The commitment for corrective action does not state specific changes to be
made to the health physics program to improve access control nor does it state
the date when full compliance will be achieved.
Supplemental Response
In a letter dated May 19, 1980, the licensee stated that immediately after the
accident, a large contractor supplied radiological control techniciat staff
was recruited to maintain access control at entrances to areas where high
radiation levels could be encountered.
In addition, any area that was identified
as having radiation levels greater than 1.0 Rem /hr was barricaded and/or
locked.
Keys to these high radiation areas were maintained by radiological
control foreman.
Any entry into these areas was escorted by radiological
control personnel who unlocked the area and performed radiation surveys prior
to and during the entry.
This practice cor.tinues to date, in accordance witi: Procedure AP 1050 " Control
Additionally, lock changes have been made to assure
that each door has a. unique lock and key.
AP 1050 will be revised and incorpor-
ated into the Radiologir.al Controls Procedures Manual for TMI-2.
This revision
was scheduled for implementation by August 31, 1980.
In November 197S, TMI-2 managem(at initiated changes in the Radiological
Control Program in an effort to achieve a strong, effective program.
The
steps initiated and planned are outlined in the Management Plan for TMI-2
Radiological Control Program presented to the NRC in February 1980.
Each
action item addressed in this plan was assigned a completion date.
Implemen-
tation of all changes addressed in this plan is expected by December 31, 1980.
On November 5, 1980 the licensee reported that the revision to AP 1050 would
be implemented by December 1, 1980.
Final Evaluation
The licensee's previous and additional corrective actions are acceptable.
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ITEM 2.B
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Specific Conclusion of January 23, 1980
The response stated that " site monitoring devices will be reevaluated and
enhanced as necessary" but did not describe specific steps to be taken nor the
date when full compliance will be achieved.
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Supplemental Response
In a letter dated May 19, 1980, the licensee stated that emergency monitoring
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equipment, dedicatca to use for emergency situations, will be placed at strategic
'ocations, such as at designated emergency high radiation area control points
und at the dosimetry building.
This equipment will be maintained in a state
of readiness at all times.
A limited number of high range equipment (dose
rate instruments and self reading dosimeters) were to be in place by June 30,
1980.
During various conversations and meetings held in September and October 1980,
the licensee provided additional specificity and/or commitments regarding
corrective actions for this noncompliance as described below.
The requirement for dosimeter usage during the TMI-2 recovery is set forth in
Article 5 of the "Three Mile Island Nuclear Station, Unit 2, Radiation Protec-
tion Plan", Revision 2, dated June 16, 1980:
"Any individual entering a High
Radiation Area shall (a) use a continuously indicating dose rate monitoring
device, or (b) use a dose rate integrating device which alarms at a preset
dose level, or (c) assure that a radiological control technician provides
periodic radiation surveillance with a dose rate monitoring device".
It is the licensee's intentions to incorporate this plan.into the administra-
tive control procedures for the TMI-2 radiological controls department (4000
Series) by December 31, 1980.
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The high range dosimeters that were to be placed at likely Emergency high
radiation areas for emergency use only are now in place.
Therefore it is a normal requirement at TMI-2 to assure quantification on a
real time basis of the dose to any worker when in a High Radiation Area.
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Also, provisions have been made to assure the availability of high range dose
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rate devices in the event of an emergency.
Final Evaluation
The licensee's previous and additional corrective actions are acceptable.
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Appendix A
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ITEM 2.C
Specific Conclusion of Janaary 23 1980
2
The commitment for corrective action states that additional air monitoring
equipment is in place, but provides no information regarding the amount of
equipment, performance capability, or intended use.
The response also states
that retraining programs will place additional emphasis on air sampling tech-
niques but the techniques to be emphasized are not described and no information
is provided regarding results achieved due to corrective steps taken.
The
date when full compliance will be achieved is not specified.
Supplemental Response
In a letter dated May 19, 1980, tne licensee stated that in addition to continu-
ous monitoring instruments capable of measuring particulate, iodine, and
gaseous levels installed since the accident, there are 26 fixed filter continuous
monitors for particulate activity in use within the TMI-2 complex.
There are,
in addition, 28 portable particulate sampling devices in ase within the TMI-2
complex for the purpose of performing grab samples in specific situations.
The following summary reflects the quantities and characteristics of all air
monitoring equipment in use at TMI-2.
RANGE
INSTRUMENT QUANTITY PARTICULATE IODINE
NOBLE GAS PERMANENT MOVEABLE
5
1.0E6 cpm
1.0E6 cpm 1.0E6 cpm
5
Eberline
4
1.0E6 cpm
1.0E6 cpm 1.0E6 cpm
4
Victoreen
13
1.0E6 cpm
1.0E6 cpm 1.0E6 cpm
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Eberli r.e
26
100,000 cpm
26
AMS-3
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Training in the use of this equipment is included in the qualification program
for all radiological control technicians and their foremen as described in
responses to Items 2.E and 8.
On November 7, 1980, the licensee reported that 32 personnel air sampling
devices (lapel samplers) are also available for use in TMI-2.
Fic11 Evaluation
The licensee's previous and additional corre.ctive actions are acceptable.
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ITEM 2.0
Specific Conclusion of January 23, 1980
The response states that certain actions are being taken which could correct
this problem such as revisions to Emergency Plan implementing procedures and
changes in retraining programs, but the specific steps which have been taken
and resul'2 achieved, the steps to be teken, and the date when full compliance
will be au...eved are not stated.
Supolemental Response
In a letter dated May 19, 1980, the licensee stated that corrective actions
described for Item 2.A, 2.B and 2.E are considered to be applicable to this
item and adequate to prevent its recurrence.
Final Evaluation-
The licensee's corrective actions, as described for Items 2. A, 2.B and 2.E,
are considered applicable to Item 2.D.
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ITEM 2.E
Specific Conclusion of January 23, 1980
More effective training of radiation workers and radiation chemistry technicians
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is. essential tn preventing recurrence of this problem, but'the response does
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not describe specific steps to be taken in this regard nor does it specify the
date when full compliance is to be achieved.
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Supplemental Response
In a letter dated May 19, 1980, the licensee stated that the actions stated ir
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2.A and 2.B above are considered applicable to this item and will aid in pre-
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venting its recurrence.
The Emergency Plan will also be modified to include
expcsure guidelines in emergency situations.
These criteria will apply the
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guidelines of the NCRP and 10 CFR 20 to the specific phases and situations
that may be~ encountered in an emergency.
All personnel qualified by the RWP
training and Radiological Control Technician training progr'ams will be instructed
in these criteria r.0'mencing June 1, 1980.
Standards for Radiological Control
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Training for Rad ological Control Technicians and their foremen were developed
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in December 1979 and training for the current radiological control technicians
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was initiated in January 1980 with a completion date of July 1,1980 for all
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currently employed radiological control technicians.
This training program
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was detailed in the Management Plan for TMI-2 Radiological Control Program.
The implementing procedure for this training program was to be issued by June
30, 1980.
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The training program consists of classroom training followed by a written
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examination, oral examinations which assess the individual's ability to identify
and respond to unusual / emergency situations, spill drills which measure the
individual's ability to react to staged unusual conditions, and practical
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factor training which determines the individual's ability to perform required
operational tasks.
Retraining will be conducted on an annual basis.
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The Radiological Safety Training Progran for all personnel employed at TMI-2
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has been revised and is currently in progress.
In addition to classroom
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instructons, emergency response and practical factor training provides opera-
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tional training in the radiological considerations applicable to the individual's
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craft lines / functions.
The implementing procedure defining this program has-
been developed and is currently awaiting final approval.
Similarly, retraining
would La cord"cted on an annual basis.
Full compliance was to be achieved by
November 1, 1980.
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On November 5, 1980,-the licensee reported that the implementing procedure for
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radiological controls technicians training will be issued by December 31,
1980.
Further, the liceniee reported that the Radiological Safety Training
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Program will be implemented by December 31, 1980.
Final Evaluation
The licensee's previous and additional corrective actions are acceptable.
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ITEMS 2_F and 2.G
Specific Conclusion of January 23, 1980
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The response states that special handling, tools, shielding, and training of
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chemistry personnel will be provided; however, this commitment lacks' specificity
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ar.d fails to address the more general area of preplanning for all radiological
. work.
No date is specified for full compliance.
Supalemental Response
1
In a let+.er dated May 19, 1980, the licensee stated that Radiological (ALARA)
Engineers currently review work requests meeting the criteria established by
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the Radiological Control Department for tasks in areas or on systems-having
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radiological implications.
ALARA engineers are on call on a twenty-four hcur
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basis to perform these reviews.
The purpose of these reviews is to assess the
radiological conditions and determine the most effective manner to perform the
task while maintaining personnel exposures as low as reasonably achievable.
Techniques considered 'n reducing exposures are; flushing operations, shielding,
- special tooling, and the use of containment systems.
In addition to operational
techniques, the need far mock-up training and/or working briefings prior to
the performance of the task are considered.
Mock-up training, worker briefings
and operational techniques were utilized on major evolutions already conducted
at TMI-2, such as the reactor building sump sampling (401 penetration) opera-
.
tion and currently on the reactor building re-entry program.
Procedures-docu-
menting the above practices and requirements were to be developed ond were
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expected to be implemented by July 1, 1980.~
A program has been implemented to review existing chemistry proceduren to
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determine their adequacy from a technical and ALARA view point and to provide
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additional training for chemistry personnel.
a
i
The construction of a new Temporary Sampling System was to be completed within
TMI-2 to replace the need to take TMI-2 samples in the TMI-1 Chemistry Laboratory.
i
,
This system was designed for high activity samples through the use of. shielding,
valve handwheel extensions, compact piping and sink arrangement.
Additionally,
the system design and operating procedures have undergone detailed ALARA
,'
reviews.
When construction was complete and startup testing was in progress, the chemists
were to receive formal training on the system that includes ALARA considerations-
}.
with the ultimate objective of further reducing dose rates during sampling
l-
evaluations'. Training was to be provided to Radiological Controls personnel in
'
handling the types of samples that will be taken at this sink.
1
On November 5, 1980, the licensee reported that ALARA procedures will be
implemented by-December 1, 1980.
,
!
Final Evaluation
i
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The licensee's previous'and additional corrective actions are acceptable.
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Appendix A
13
ITEM 2.H
Specific Conclusion of January 23, 1980
No specific corrective steps were specified for assuring more prompt evaluation
'
of personnel contamination in the future.
Supplemental Response
In a letter dated May 19, 1980, the icensee stated that instrumentation
<
'
necessary for rapid evaluation of personnel contamination is currently available
'
and radiological controls technicians have been trained in its use.
Documentation
of skin contamination is being accomplished in accordance with an existing
procedure HPP 1612 " Monitoring for Personnel Contamination".
A new procedure
describing the evaluation, handling, and documentation of skin contamination
'
situations is currently being developed and is scheduled for implementation
i
prior to September 1, 1980.
Thumbrules for rapid evaluations (for reaction
purposes only) have been developed as field use tools for technicians during.
unusual / emergency situations.
These thumbrules have been introduced to the
technicians during emergency response training sessions.
Formal evaluations
of personnel exposures resalting from skin contiminations are and will be
performed by professional and Technical individuals within the Radiological
Technical Support and Radiological Support Serives groups of the Radiological
Control Department.
The above described conditions are considered to be
adequate corrective actions for the cited deficient conditions.
Final Evaluation
The licensee's previous and additional corrective actions are acceptable.
2
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Appendix A
14
.
ITEM 3
Statement of Noncompliance
Technical Specification 6.5.1, " Plant Operations Review Committee," requires
in Section 6.5.1.6.a
that the Plant Operations Review Committee (PORC) review
all procedures (and changes thereto) required by Technical Specification 6.8
and any other procedure (or change) determined to affect nuclear safety.
Contrary to the above, inadequate reviews were performed on both Procedure
Change Request No. 2-78-707, Revision 4 to Surveillance Procedare 2303-M27A/B,
and Procedure Change Request No. 2-78-895, Revision 8 to Surveillance Procedure
2303-H14A/B/C/D/E; both were reviewed and approved by the PORC (November 9,
1978 and August 15, 1978 respectively).
Each approved change included a valve
111eup which resulted in emergency feedwater header isolation, contrary to
Technical Specification 3/4.7.1 requirements.
Conclusion of January 23. 1980
The item as stated is an item of noncompliance.
The information provided ry
the licensee does not provide a basis for modification of the enforcement
action.
t
The licensee should address in a supplemental response the actions to be taken
to assure PORC members have the necessary technical expertise to demonstrate a
clear understanding of the implications of TS requirements and system operability
requirements as stated in the TS and FSAR.
The specific further examples of
similar test procedures contained in the resnonse of the licensee should be
included in the review of procedures planned by the licensee.
The licensee should also address an appropriete target date for the completion
,
of these reviews.
4
.
'
Supplemental Response
'
In a letter dated May 19, 1980, the licensee stated that the TMI-2 PORC has
undergone major changes since the March 28, 1979 accident.
The major changes
l
are as follows:
.
(1) A Supervisor-Technical Specification Compliance position has been established.
A primary responsibility of this posit' of is that of serving as full time
PORC Chairman.
Day to day involvement with Technical Specification (TS)
matters creates an inherent TS expertise.
I
(2) The new TMI-2 Recovery TS implement revised PORC membership requirements.
Specifically, the Plant Operations Review Committee shall be composed of
the following members:
,
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Appendix A
15
(a) Chairman
who shall have an academic degree in engineering or
physical science field and a minimum of five years of applicable
experience.
(b) 1 Member
who shall meet or exceed the qualifications of Regulatory.
Guide 1.8, September 1975.
(c) 7 Members - who shall meet or exceed the qualifications of Section
4.4 of ANSI N18.1 - 1971.
The PORC membership has been significantly changed to include a broader
spectrum of expertise and background.
(3) The PORC review philosophy has evolved to emphasize the broader safety
questions, TS compliance, CFR compliance, etc.
This approach has already
resulted in a marked improvement in PORC reviews.
(4) The Recovery TS were issued by NRC Order of February 11, 1980.
To assure
a clear understanding of the implications of TS requirements and system
operability requirements all PORC members have been provided a copy of
the TS.
They will be required to document their rev 'ew and understanding.
Further, as TS changes occur PORC is required to review the changes prior
to submittal to the NRC.
Therefore, there is an inherent mechanism for
keeping abreast of changes to the TS.
This documentation is now complete.
During various conversations and meetings held in September and October 1980,
the licensee provided additional specificity and/or commitments regarding
corrective actions for this noncompliance as described below.
To adequately perform the PORC review function selection has been made of a
broad range of " staff specialists" as referred to in ANSI 18.1 to provide the
breadth and depth of review consistent with the matters reviewed.
Therefore,
the training which is related to PORC members. is that professional training
and experience which has prepared and is a part of eact member.
Members have
received either at least formal Baccalaureate training, hold degrees, and have
a minimum of 3 years of professional level experience in the field of his
specialty, or have at least 8 years of experience in a specialized field.
Many members have further documented specialized training.
These reccrds are
!
on file by the licensee.
PORC members will receive initial training and periodic retraining on a two
(2) year cycle in the following areas:
Reactor Safety and Safety Analysis;
TMI-2 Technical 5;.ecifications; and, Industry Experier.ce Review, Reportable
events at other units, IE Bulletins, Information Netices and Circulars.
This training will be given all' current PORC members and to all new members
before they participate in PORC activities.
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Appendix A
16
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4
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The continuing training by the respective PORC members also consists of that
!
similar specialized training, formal and informal, which he receives during
1
the course of his professional activities.
Training provided by the licensee
is documented in accordance with Training Department Administrative procedures,
hence training received in the past and on a continuing basis is formally
documented.
Examples of this additional training which is provided to applicable
i
!
PORC members include Senior Operator Qualification Training, Simulator Training,
!
Semina s, College Engineering Courses, Unit 2 Systems Training, and Technical
l
Specification Training.
t
Periodic training in Industry Experience Review will be accomplished during an
,
individual's PORC membership.
,
The PORC training program will begin by February 28, 1981.
The training
i
'
activities will be approved by the PORC Chairman and the Manager TMI-2, for
.
adequacy of the couise content and effectiveness of its accomplishment and
'
will be audited by the Q/A department as part of the biennial review.
i
The PORC is composed of a broad range of expertise.
However, when the required
i
range of expertise is not represented to adequately address matters brought
,
i
before the group, the PORC Chairman (and any PORC member) is responsible to
obtain the necessary expertise and assure' the quorum is present.
This is done
in various ways, depending upon the need, such as having required expertise tc
attend the meeting, and/or obtaining expert input to the meetings, etc.
The
expertise available may be the licensee or the contractor / consultant personnel.
,
j
Minutes of the PORC meetings reflect the input by and participation of such
experts, by name.
l
The PORC has not been changed with the facility's reorganization except that
it has been strengthened by the naming of a dedicated full-time PORC Chairman
e
position and providing for a full-time PORC Administrator.
7
Final Evaluation
.
The licensee's previous and additional corrective actions are acceptable.
,
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Appendix A
17
ITEM 4.A
Statement of Noncompliance
Technical Specification 6.8, " Procedures," requires in Section 6.8.1 that pro-
,
cedures be established, implemented and maintained covering identified activities.
Emergency Procedure 2202-1.5, " Pressurizer System Failure," Revision 3, requires
in Section A.2.B.1 that electromatic relief isolation valve RC-R2 be closed
if, among other things, the valve discharge line temperature exceeds the
4
normal 130 F.
Contrary to the above, the electromatic relief valve discharge line temperature
had been in the range of 180'-200 F since October o 1978 and isolation valve
RC-R2 was not closed as of 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> on March 28, 1979.
Additionally, on
March 28, 1979, the discharge line temperature of 238 F was noted at 0521
hours, but the isolation valve RC-R2 was not closed until 0619 hours0.00716 days <br />0.172 hours <br />0.00102 weeks <br />2.355295e-4 months <br />, allowing
a significant loss of RC inventory.
Conclusion of January 23, 1980
.
The item as stated is an item of noncompliance.
The information presented by
the licensee does not provide a basis for modification of the enforcement
i
action.
The corrective actions proposed by the licensee to prevent recurrence of
similar conditions lack the specificity to permit evaluation.
It is understood
'
that the specific revisions to the PORV as regards position indication and
leakage determination will be part of the review of the restart proposal for
TMI-1 and, at some later date, TMI-2.
However, the licensee should address in
a supplemental response 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.
Sucolemental Response
In a letter dated May 19, 1980, the licensee stated that management has recently
issued a policy statement regarding compliance with Operation and Maintenance
procedures.
Additionally, a series of meetings are being conducted with
Operations Department personnel to address the need to comply with procedures
and personnel responsibilities for. identifying when procedures require revisions.
Instructions were issued to all applicable personnel enforcing management's
position on February 15, 1980.
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Appendix A
18
Dur'ng various conversati,ns and meetings held in September and October 1980,
the licensee provided additionai specificity and/or commitments regarding
corrective actions for this noncompliance as described below.
The licensee maintaned that the underlying cause of this event was that the
procedure identified a temperature of 130 F as " normal" when the actual normal
temperature was in the 170 -190 F range.
To prevent a recurrence of this
problem, the need for literal compliance with procedures and the requirement
that procedures which cannot be literally complied with be promptly revised,
have been reemphasized by management to operating personnel.
It was made clear that management requires that operators recognize and identify
to the shift supervisor any inadequacy in procedures or change in plant conditions
which make a procedure incorrect.
When an operator recognizes a problem in a
procedure based on the understanding of plant conditions or an inherent problem
with the procedure, he will stop the evolution at a point at which the plant
is in a safe condition and will notify the shift superviscr for resolution.
The shift supervisor is responsible to ensure that the necessary procedural
changes are issued promptly.
This above emphasis was formalized by a memo from Mr. P.
P,. Clark, Vice-President,
GPUSC, dated March 7, 1980.
However, because of the fundamental importance of
the matter, rather than to convey the strong feelings of management by simply
distributing the written statement, management discussed tne matter directly
with operating personnel in April,1980.
The licensee considered that the communication of management policy by face-to-
face discussion, wherein questions could be asked and answered and the sincerity
of management on the subject made abundantly clear, was very effective.
This action is being supplemented by incorporation of the thrust of Mr. Clark's
directive into a new procedure which will supercede Administrative Procedure
1001.
This new procedure was to be in place by November 17, 1980, and will be
implemented after a period appropriate for familiarization and learning.
This
procedure will give added guidance as to how this management directive is to
be implemented.
While the prompt follow up to Mr. Clark's memo was directed
at operating people, the incorportion of this emphasis and its impler.entation
into the new procedure will communicate the strong management feeling to all
who use TMI-2 procedures.
Final Eve'uation
The licensee's previous and additional corrective actions are acceptable.
-
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.
Appendix A
19
ITEM 4.8
Statement of Noncompliance
Technical Specification 6.8, " Procedures," requires in Section 6.8.1 that pro-
cedures be established, implemented and maintained covering identified activities.
B.1 Emergency Procedure 2202-1.3, " Loss of Reactor Coolant / Reactor Coolant
System Pressure," Revision 11, requires in Sections B.2.2.3, B.3.6.2 and
A.3.2.B:
that high pressure injection is initiated on low RCS pressure
(1600 psig), and that the operator verify high pressure injection is
operating properly as evidenced by flow in all four legs (250 gpm); that
flows be maintained at this rate by throttling as RCS nressure drops; and
that high pressure injection not be terminated until RLJ pressure can be
maintained above the reset point (1540 psig) or until low pressure injection
,
flow is established at 3000 gpm.
Contrary to the above:
1.
At about 0405 on March 28, 1979, high pressure injection flow was
throttled to minimum conditions even though RCS pressure was less
than 1600 psi and falling, and without Ic.1 pressure injection flow
established.
2.
At various times throughout the day of March 28, 1979, the high
pressure injection system was modified such that the required flow
rates were not maintained during continuing low pressure conditions
within the RCS following the period when the reactor coolant pumps
were stopped and the high pressure injer. tion system was the only
mode available for the removal of core decay heat.
B.2 Emergency Procedure 2202-1.3, " Loss of Reactor Coolant / Reactor Coolant
System Pressure," Revision 11, requires certain actions to be taken
following the automatic initiation of high pressure injection, including
in Section B.3.1, that all ESF equipment is verified to be in its ESF
position (capable of performing its intended 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 28, 1979, during continuing low pressure condi-
tions within the RCS, the Core Flood System was removed from its ESF
position (rendered inoperable) by closing both tank isolation valves.
,
(This portion of the ESF was inactivated during a period when reduction
of Reactor Coolant System pressure was not the immediate goal.
This
removed from service this safety feature during a period when it_could
have been called upon.
In the course of the accident while attempting to
depressurize to activate the decay heat removal system NRC recognized
that it was necessary to isolate the core flood system and encouraged
this action.
This citation does not apply to isolation during this
attempt.)
.
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Appendix A
20
Conclusior, of January 23, 1980
Item 4.B.1 as stated is an item of noncompliance.
The corrective actions
proposed by the licensee appear adequate to preclude recurrence.
These procedure
reviews and. improvements will be subject to review during evaluation of the
restart proposal for Unit 1 and, at a later date, Unit 2.
Item 4.B.2 as stated is an item of noncompliance.
The licensee should address
in a supplemental response those measures to be taken to insure that the
operability requirements of Engineered Safety Features are met during all
phases of operation.
The information provided by the licensee for Items 4.B.1 and 4.B.2 does not
provide a basis for modification of the enforcement action.
Sucolemental Response
In a letter dated May 19, 1980, the licensee stated the Core Flood Valves
which are the subject of this infraction are not required to be operable in
the current Technical Specification for TMI-2.
Administrative Procedure No.
1012 requires a shift ES checklist to be completed to reflect current plant
status of ES components.
This checklist is not required to be filled out
currently on TMI-2 because of current. plant status, 125 F (T Average).
However,
TMI-2 currently is utilizing a procedure, " Shift & Daily Checks," Procedure
4301-51, which is used to verify that those systems / components required by the
current Technical Specifications are in the necessary State of Readiness.
'
Additionally, Operations Department personnel have been instructed to comply
with approved procedures.
The action required by this item is considered
complete.
Final Evaluation
The licensee's corrective measures are acceptable, as previously discussed in
NRC's letter of January 23, 1980 and licensee letter of May 19, 1980.
.
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Appendix A
21
ITEM 4.C
Final Evaluation
The licensee's corrective measures are acceptable, as previously discussed in
the NRC's letter c' January 23, 1980.
.
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Appendix A
22
ITEM 4.D
Statement of Noncompliance
Technical Specification 6.8, " Procedures," requires in Section 6.8.1 that pro-
cedures be established, implemented and maintained covering identified activities.
Emergency Procedure 2202-2.2, " Loss of Feedwater," Revision 3, requires in
Section 2.8.2.d that the operator adjust feed flow to control steam generator
levels at 30 inches.
Contrary to the above, from approximately 0532 hours0.00616 days <br />0.148 hours <br />8.796296e-4 weeks <br />2.02426e-4 months <br /> until 0543 hours0.00628 days <br />0.151 hours <br />8.978175e-4 weeks <br />2.066115e-4 months <br />, the
level in A steam generator decreased to 10 inches (the minimum level indication)
while the A steam generator level was being controlled manually.
Conclusion of January 23, 1980
A review of the circumstances and actions involved with this item shows that
the licensee failed to maintain the steam generators at the desired level.
However, this review showed that this item was not a noncompliance.
We are
concerned that the licensee failed to maintain a heat sink to provide a means
to cool the core. The licensee is requested to address in a supplemental
response the actions to be taken, including procedural improvements, to establish
the reouired steam generator water level in all modes of feedwater or emergency
feedwater addition.
Suoplemental Response
In a letter dated May 19, 1980, the licensee stated that procedures establishing
required steam generator water level for the recovery mode are in place.
During various conversations and meetings held in September and October 1980,
the licensee provided additional specificity and/or commitments regarding
actions taken for this item as described below.
.
The feedwater to the "A" Once Through Steam Generator (OTSG) is now normally
from one of the three condensate pumps with further backup by the EFW pumps.
While the condensate pumps are not provided with access to emergency power,
- the two EFW. pumps are able to be connected to the emergency diesels.
OTSG 1evel is maintained by manual control of feedwater flow.
Because of the
much less rapid change in steam generator water level on' loss of feedwater in
current operational mode compared to normal reactor operation, the licensee
reports that such control has been found to be satisfactory.
i
For the same reason, there is no provision now for automatic switch-over to
'
any of the five backup pumps, manual changing being satisfactory at the very
low steaming rate.
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Appendix A
23
Operation of the condensate and EFW pumps is performed under procedures used
prior to the accident.
Control of feedwater is according'to Revision 8 of
.
'
Procedure 2106-2.4.
s
j
Other potential heat removal modes such as the Mini Decay Heat Removal (MDHR)
'
System or " Loss to Ambient" do not involve steaming and accordingly require no
feedwater or feedwater control.
'
>
.
Final Evaluation
!
.;
The licensee's. completed actions are acceptable.
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Appendix A
'24
ITEM J.E
Statement of Noncompliance
Technical Specification 6.8, " Procedures," requires in Section 6.8.1 that pro-
cedures be established, implemented and maintained covering ider.tified activities.
Three Mile Island Nuclear Station Administrative Procedure 1004, "Three Mile
Island Emergency Plan 1004," Revision 2, dated February 15, 1978:
1.
Requires in Section 2.1 that the " Station Superintendent / Senior Unit
Superintendent, Unit Supt./ Shift Supervisor / Unit Supt. - Technical Support
in the Control Room will, after reviewing the emergency conditions,
classify the emergency as one of the following:
"a.
Personnel or Local Emergency,
"b.
Site Emeegency, and
"c.
General Emergency
"He will make this classification according to the condition of Table 1
of this plan, and initiate actions according to the Emergency Plan Imple-
menting Frocedures, and according to his own best judgment;" and
2.
States in Table 1 of Section 2.1 that a Site Emergency exists when there
is a reactor building high range gamma monitor alert alarm (Condition Nn.
e).
Contrary to the above:
1.
Adequate written procedures were not established and implemented in that
Section 2.1 cf Procedure 1004 for implementing the Emergency Plan lacked
sufficient specificity and failed to result in a Site Emergency being
declared at approximately 0430 on March 28, 1979, even though primary
system pressure had decreased to the point where safety injection was
automatically initiated and a reactor building sump high level alarm
existed; and
2.
A site emergency was not de.clared at 0635 hours0.00735 days <br />0.176 hours <br />0.00105 weeks <br />2.416175e-4 months <br /> on March 28, 1979, at
i
which time Condition "e" of Three Mile Island Emergency Plan 1004 had
occurred.
Conclusion of January 23, 1F80
Item 4.E.1 as stated is an item of noncompliance.
Item 4.E.2 is withdrawn.
The corrective action specified is incomplete in that the date fall compliance
is to be achieved is not specified.
A supplemental response is requested to
provide this information.
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Appendix A
25
Supplemental Response
In a letter dated May 19, 1980, the licensee stated that TMI-2 is revising its
Emergency Plans to incorporate revised criteria such as those contained in
1
The revised plan will be implemented consistent with the implementa-
tion of the TMI-1 pian which has already been submitted to the NRC.
Drills are now being conducted on a quarterly basis in TMI-2.
When the new
plans and implementing procedures are approved for use, drills and emergency
preparedness will be conducted in accordance with them.
4
It was expected that the new plans will be phased in during the month of July
1980.
A drill was to be planned in concert with the NRC, PEMA, BRP and others.
The drill was scheduled for July 16, 1980 and the entire emergency management
organization was to be exercised.
'
Notification and emergency action level criteria per NUREG-0610 (also 0654)
were implemented as of February 22, 1980 as an interim measure until the new
plan is in effect.
This interim instruction also implements the new notifi-
cation criteria per 10 CFR 50.72.
On November 5, 1980, the licensee reported that all Emergency Plan implementation
procedures related to TMI-2 have been reviewed and updated to reflect (a)
existing types, locations, and uses of facilitiec, and (b) action levels based
on currently installed instrumentation and environmental surveillance functions
reflective of recovery operations at the TMI-2 site.
A copy of the updated
procedures was forwarded to the NRC on October 20, 1980.
On November 5, 1980, the licensee also reported that the revised Emergency
Plan will be submitted to the NRC on January 2,1981.
Final Evaluation
The licensee's previous and additional corrective actions are acceptable.
i
?
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- -
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.
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Appendix A
26
ITEM 4.F
Final Evaluation
The licensee's corrective measures are acceptable, as previously discussed in
the NRC's letter of January 23, 1980.
.
t
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Appendix A
27
ITEM 4.G
Final Evaluation
The licensee's corrective measures are acceptable, as previously discussed in
the NRC's letter of January 23, 1980.
.
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Appendix A
28
ITEM 5
Final Evaluation
The licensee's corrective measures are acceptable, as previously discussed in
the NRC's letter of January 23, 1980.
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Appendix A
29
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ITEM 6
!
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Statement of Noncompliance
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!
Environmental Technical Specification 5.7 requires (Sat detailed writte- gro-
!
cedures for instrument calibration be prepared and followed.
l
Three Mile Island Nuclear Station Surveillance Procedure 1302-5.24, Revision
?, dated December 19, 1974, specifies the method of calibration and requires
4
that it be performed anrJally.
'
Contrary to the above, as of March 29, 1979, eight environmental samplers had
not been calibrated since 1974.
,
!
2
Conclusion of January 23, 1980
The item as stated is an admitted item of noncompliance.
The information
provided by the licensee does not provide a basis for modification of this
enforcement action.
The licensee is requested to submit a supplemental response
'
addressing the areas described below.
The corrective action commitment is not
acceptable because it does not provide a commitment for instrument calibration
and does not specify the date by which full compliance will be achieved.
4
Suoclementcl Response
,
In a letter dated May 19, 1980, the licensee stated that calibration of the
!
off-site continuous air samplers is done on an annual basis during the first
week of February.
It is performed by the Instrumentation and Control Group.
The procedure followed is Surveillance Calibration Procedure 1302-5.24; this
procedure was to be revised and was expected to be approved by June 1, 1980.
,
On November 5,1980, the licensee reported that Procedure 1302-5.24 will be
approved by November 15, 1980.
Final Evaluation
.
f
The licensee's previous and additional corrective actions are acceptable.
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.
Appendix A
30
ITEM 7
Final Evaluation
The licensee's corrective measures are acceptable, as previously discussed in
the NRC's letter of January 23, 1980.
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Appendix A
31
ITEM 8
Statement of Noncompliance
-
Technical Specificaton 6.4, " Training," requires that a retraining and replace-
ment training program for the unit staff be maintained that meets 3r exceeds
the requirements and recommendations of Section 5.5 of ANSI N18.1-1971.
Contrary to the above, as of March 28, 1979, a retraining program meeting or
exceeding ANSI N18.1-1971 recommendations had not been maintained for members
of the radiation protection and chemistry staff in that only 2 of the 10
top'cs recommended were included in the program.
j
Conclusion of January 23, 1980
j
The item as stated is an item of noncompliance.
The information provided by
the licensee does not provide a basis for modification of this enforcement
.
'
action.
A supplenental response is requested to provide more specific training commit-
,
ments for radiation protection and chemistry staffs.
Suoclemental Response
,
!
In a letter dated May 19, 1980, the licensee stated that the ten items in
Section 5.5 of ANSI N18.1-1971 referenced in this item are specific to Operator
-Replacement and Requalification Training.
This is further amplified in the
j
1978 edition of the standard.
!
l
The Radiological Control Technicians qualification program, described in the
responst to Item 2.E, is an annual recurring program.
Training on the ten
!
items listed in Section 5.5 of ANSI N18.1-1971 will be presented as applicable
to conditions present at TMI-2 and only in the detail necessary to the perform-
ante of the Radiological Control Technicians'. duties and responsibilities as
an integral part of this training.
I
A Chemistry Technician Training Program for TMI-1 and TMI-2 was being developed
that was job related.
It would contain a program for newly-hired technicians
l
and incumbent Technicians / Foremen similar to the HP Programs.
This program would contain lectures in basic theory, systems and procedures.
including instrumentation necessary to prepare and maintain chemistry personnel
proficient in their assigned job.
i
,
The ten items in Section 5.5 ANSI N18.1-1971 would be addressed to give the
Technicians a general understanding of the plant operations with specific
emphasis on his role in the overall plant' evolution.
- - -
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Appendix A
32
This program would be available to commence on or before June 1, 1980.
Final Evaluation
The licensee's previous and additional corrective actions are acceptable with
respect to Radiological Control and Chemistry Technicians / Foremen.
Similar
corrective actions appear necessary for other members of the licensee's radio-
logical controls staff.
These matters are further discussed in separate NRC
correspondence describing the Region I Health Physics Evaluation of TMI-1
conducted during July and August 1980.
.
8
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,
,
-
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,
.
Appanr44x A
33
ITEM 9
Final Evaluation
The licensee's corrective measures are acceptable, as previously discussed in
the NRC's letter of January 23, 1980.
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Appendix A
34
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ITEM 10.A
Statement of Noncompliance
,
)
10 CFR 20.401, " Records of surveys, radiation monitoring, and disposal,"
requires in Section (a) that each licensee maintain records showing the radia-
.
tion exposure for all individuals for whom personnel monitoring is required on
f
,
a Form NRC-5 or equivalent and in Section (b) requires that each licensee
,
I
maintain records of the results of surveys required by 10 CFR 20.201(b).
Contrary to the above:
.A.
The results of approa'mately 500 ground level radiation surveys conductea
during March 28-30, 1979 in offsite areas bordering the Three Mile Island
site were not docunanted in a manner which permitted a precise eve'uation
of the type of radiation (Beta / Gamma) which existed in the environs.
'
Pertinent information such as the type of instrumentation used and whether
-the end window on the probe was open or closed was not recorded.
'
Conclusion of January 23, 1980
The item as stated is an item of noncompliance.
The information provided by
the licensee does not provide a basis for modification of this enforcement
4
action.
The commitment for corrective action is acceptable except that.the
,
date when full compliance will be achieved is not specified.
Suculemental Response
In a letter dated May 19,-1980, the licensee stated that the proposed corrective
action for Item 10.A (the development of survey forms to improve the quality
and clarity of future off-site survey records and including these forms in
emergency kits and other locations as appropriate) would be completed by July
1, 1980.
.
On November 5, 1980, the licensee reported that corrective action was completed
,
by September 1, 1980.
-
Final Evaluation
'
'
The licensee's previous and additional corrective actions are acceptable.
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Appendix f
35
ITEM 10.8
Final Evaluat s
The licensee's corrective mer.sures are acceptable, as previously discussed in
the NRC's lette.' of January 23, 1980.
.
&
,
'
.
.
Appendix A
36
ITEM 11
,
gtementofNoncompliance
10 CFR 50, Apper., i 6, Criterion X, " Inspection," requires that a program for
inspection of activities affecting quality shall be established and executed
to verify conformance with documented instructions, procedures and drawings
for accomplishing the activity.
Three Mile Island Nuclear Station - Unit 2, Final Safety Analysis Report,
Chapter 17.2.15,Section X, requires that the inspection program include
random observation of operations and functionel testing by individuals independent
of the activity being performed.
Procedure GP 4014, "OQA Surveillance Program," Revision 0, requires independent
observation of activities affecting quality to verify conformance with established
requirements utilizing both inspection and auditing techniques...for compliance
with written procedures and the Technical Specifications.
Contrary to the above, as of March 28, 1979, the normal operations surveillance
testing activities had not been made subject to random and/or routine inspecticas
by independent methods.
Conclusion of January 23, 1980
This item of noncompl %nce is withdrawn.
"+tropolitan Edison stated in its
response that it is planning to expand its program for inspection of surveillance
testing activities.
In view of this, a supplemental response is requested
which addresses the specific requirements, and methods of implementing these
requirements, concerning the inspection of activities as they are performed.
j
Supplemental Response
'
In a letter dated May 19, 1980, the licensee stated that the Three Mile Island
i
Unit Two Recovery Quality Assurance Plan, Revision Zero is the document which
will describe the specific requirements to be used by the licensee in its
l
program for inspection and monitoring of surveillance testing activities.
This plan was in final management review and was subject to regulatory acceptance.
This plan contained a description of a Recovery Quality Assurance Monitoring
Program and independent groups which would have primary responsibility to
'
perform reviews and monitoring of surveillance testing activities.
These
3
monitorings and reviews are in addition to the Quality Control inspection
i'
witness ~and hold points which were being performed prior to the TMI-2 accident
on both units.
Monitors would be qualified in accordance with a documented QA
Department procedure that insured tnat they were knowledgeable in the activities
,
, . * *
Appendix A
37
they are monitoring to the extent that they can readily verify conformance or
compliance of the activity being performed.
Use of SR0 capable individuals
and experienced technical personnel is emphasized in the program.
Monitoring
reports will be distributed to supervisory or managerial personnel that have
responsibility for the perfarmance of the activity and nonconformance documents
will be issued when nonconformances are identified so that appropriate corrective
action, including that to prevent recurrence, can be taken by management.
Records of the program will be ina;ntained to provide adequate confirmation of
the program.
Final Evaluation
The licensee's previous and additional corrective actions are acceptable.
,
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