ML19344D917
| ML19344D917 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/18/1980 |
| From: | Swartz L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Herbein J, Keck H, Trowbridge G ANTI-NUCLEAR GROUP REPRESENTING YORK, METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| References | |
| NUDOCS 8008260348 | |
| Download: ML19344D917 (3) | |
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UNITED STATES yV NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555 o-
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August 18, 1980
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Multiple Addressees (See Attached List of Parties)
In the Matter of METROPOLITAN EDISO.1 COMPANY, ET AL.
(Three Mile Island Unit 1)
Docket No. 50-289
Dear Parties:
Attached is a copy of a letter from J. G. Herbein of Metropolitan Edison Company to Victor Stello of the NRC Office of Inspection and Enforcement for
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your review. The letter concerns the Notice of Violation and imposition of civil penalties.
Sincerely, N
Lucinda Low Swartz Counsel for NRC Staff
Enclosure:
As stated cc w/ enclosure:
Ivan W. Smith, Esq.
Dr. Walter H. Jordan Dr. Linda 11. Little l
l 8 00noan Y
V LIST OF PARTIES George F. Trowbridge, Esq.
Mr. Thomas Gerusky Shaw, Pittman, Potts & Trowbridge Bureau of Radiation Protection 1800 M Street, N.W.
Dept. of Environmental Resources Washington, D. C.
20006 P. O. Box 2063 Harrisburg, Pennsylvania 17120 Karin W. Carter, Esq.
505 Executive House Mr. Marvin I. Lewis P. O. Box 2357 6504 Bradford Terrace Harrisburg, Pennsylvania 17120 Philadelphia, Pennsylvania 19149 Honorable Mark Cohen Metropolitan Edison Company 512 D-3 Main Capital Building ATTN:
J. G. Herbein, Vice President Harrisburg, Pennsylvania 17120 P. O. Box 542 Reading, Pennsylvania 19603 Mr. Steven C. Sholly 304 South Market Street Ms. Jane Lee Mechanicsburg, Pennsylvanic 17055 R.D. 3; Box 3521 Etters, Pennsylvania 17319 John Levin, Esq.
Pennsylvania Public Utilities Comm.
Walter W. Cohen, Consumer Advocate Box 3265 Department of Justice Harrisburg, Pennsylvania 17120 Strawberry Square,14th Floor Harrisburg, Pannsylvania 17127 l
Hs. Frieda Berryhill, Chairman Coalition for Nuclear Power Plant Holly S. Keck Postponement Anti-Nuclear Group Representing York 2610 Grendon Drive 245 W. Philadelphia Street Wilmington, Delaware 19808 York, Pennsylvania 17404 Chauncey Kepford Ms. Ellyn R. Weiss Judith H. Johnsrud Sheldon, Harmon, Roisman & Weiss Environmental Coalition on Nuclear Power 1725 I Street, N.W.
433 Orlando Avenue Suite 506 State College, Pennsylvania 16801 Washington, D. C.
20006 I
Robert Q. Pollard Jordan D. Cunningham, Esq.
l Fox, Farr and Cunningham l
609 Montpelier Street 2320 North 2nd Street l
Baltimore, Maryland 21218 Harrisburg, Pennsylvania 17110 l
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l Allen R. Carter, Chairman Ms. Marjorie M. Aamodt Joint Legislative Committee on Energy R.D. #5 Post Office Box 14?
Coatesville, Pennsylvania 19320 Suite 513 Senate Gressette Building
- Atomic Safety and Licensing Appeal Board Columbia, South Carolina 29202 U. S. Nuclear Regulatorf Commission Theodore A. Adler, Esq.
WIDOFF REAGER SELK0WITZ & ADLER
- Atonic Safety and Licensing Board Panel 3
Post Office Box 1547 U. S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17105 W. ashington, D. C.
20555 Ms. Karen Sheldon
- Docketing and Service Section i
Sheldon, Harmon, Roisman & Weiss U. S. Nuclear Regulatory Commission 1725 I Street, N.W.
Washington, D. C.
20555 Suite 506 Washington, D. C.
20006 i
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Metropolitan Edison Company "9 h.7 d Is,
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Post Office Box 480 gj Middletown. Pennsytvania 17057 717 9444041 Wnter's Direct Dial Numtwr July 21, 1980 p,j g g TI.L 340 Office of Inspection and Enforce =ent Attn:
V. S*.el30, Director U. S. Nuclea. Regulatory Co==ission Washington, b.C.
20555
Dear Sir:
Three Mile Island Nuclear Station, Unit I (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Responses to Ite=s of Non Co=pliance On October 25, 1980, the NRC trans=itted a Notice of Violation and a Notice of Proposed I= position of Civil Penalties in the a=ount of $155,000.
On Dece=ber 15, 1980 Metropolitan Edison Co=pany responded to these notices and received a response from the NRC on January 23, 1980 addressing both units.
On March 6, 1980 a =ecting was held between = embers of the NRC Inspection and Enforcement Region I office and those of Metropolitan Edison Co=pany.
At this =eeting it was agreed that a final sub=ittal would be sent for Unit II (May 19, 1980) and that corrective action for Unit I would be co=pleted on a schedule co==ensurate with the restart of TMI-I.
To this end, enclosed please find the response for TMI-I.
Sincerely, s
J. G. Herbein Vice President TMI-I JGH:LWH: hah cc:
J. T. Collins i
B. J. Snyder B. H. Grier H. Silver R. W. Reid D. Dilanni bY goo 72906/7 Metrocontan Ecson Comaam is a Member of the Genera! Pcc Wies System
%d 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 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 dur.ing the conduct of erth 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 IMI-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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s ITEM 2 Provide a supple = ental response conce.rning 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 co:pliance; 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. Met-Ed is in the process of thoroughly reviewing and appropriately revising the approxiestely 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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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 so demonstrate cicar understanding of the Technical Specifications (TS) requirements and system operability requirements as stated in the TS and FSAR.
RESP 0NSE 3 THI-I organization, including onsite and offsite review functions and review group composition are currently under review by Met-Ed.
An accadment to Section 5 I the TMI-I Restart Report, scheduled for submission by August 1,1980, will address the membership and responsibilities of these casite and offsite groups, including PORC. A proposed Technical Specification Change vill be submitted subsequent to the Restart Report Amendment reflecting all organizational changes.
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ITEM 4 A.
Provide in a supplemental response those steps being taken to assure that changed plant operating conditions will be factored pro =ptly into emergency and opcrating 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 measures taken to insure that operability requirements of the Engineered Safety Features are met during all phases of operation.
C.
Provide the actions to be taken, including procedural i=provecents, to establish the required steam generator water level in all modes of feedwater or emergency feedwater addition.
D.
Provide the date of full co=pliance in regards to AP 1004 TMI Emergency Plan.
RESPONSE 4 TMI-I procedures have undergone extensive review and revision. Four ad=inistrative procedures; AP 1001 Document Control AP 1002 Switching and Tagging AP 1016 Operations Surveillance Progra=
AP 1010 Technical Specification Surveillance Program have or are being revised to ensure redundant loops of safety related equipment are not inoperable and that equip =ent is properly returned to service following surveillance or maintenance (see also TMI-I Restart Report. Section 2).
Revisions to operating, surveillance and caintenance procedures to incorporate NRC require-ments and Restart Report commitments are substantially co=plete with regard to equipment 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 4
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 rnd the importance of procedural co=pliance as described in the TMI-I Restart l
Report, Section 6.
Revision 2 of TMI Unit I Emergency Plan was submitted to NRC for review on June 10, 1980.
Approximately 35 Emergency Plan Implenenting 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 canager prior j
to finalization.
Met-Ed estimates that the EPIP's will be finalized by September l
1, 1980.
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x ITEM 5 Provide a supplemental response concerning the review and approval of procedures implementing the Emergency Plan.
RESPONSE 5 Revision 2 of IMI-I Emergency Plan was submitted to NRC for review in early June, 19S0.
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 (or their successors) prior to finalization. Met-Ed estimates that the Emergency Plan Implementing Procedures will be finalized by September 1, 1980.
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.q ITEM 6 Provide a supplemental response addressing the calibration of environmental air samplers.
RESPONSE 6 Met-Ed's response ti, this item for TMI-II dated May 19, 1980, identified corrective action taken relative to offsite continuous air sa=plers. 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 organization are currently addressed in Section 5 of the TMI-I Restart Report which is scheduled for revision by August 1, 1980. A proposed Technical Specification change will be submitted subsequent to the TMI-I Restart Report amendment reflecting all organizational changes.
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ITEM 8 Provide a supplemental response addressing the retraining and replacement training progras for the unit staff which meets the require =ents of ANSI N 18.1-1971.
RESPONSE 8 Tne response to Ite= 8 of the May 19, 1980' letter also applies to TMI-I (See TMI-I Restart Report Section 6).
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M ITDi 9 Provide a supplemental response addressing Reactor Coolant System Leakage.
RESPONSE 9 IMI-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 (GPM). 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 O
Provide a supplemental response addressing records of surveys, radiation monitoring and disposal retention.
RESPONSE 10 The response to Item 10 of the May 19, 1980 letter also applies to TMI-I.
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ITDi 11 Provide a supple = ental response addressing the specific require =ents and nethods of 1:ple=enting these require =ents concerning the inspection of activities affecting quality as they are perfor=ed..
RESPe:SE 11 The response to Ite= 11 of the May 19, 1950 letter also applies to 2(I-1 Revision 8 to the Operational Quality Assurance Plan is contained in the 2(I-I Restart Report Supple:ent 2.
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