ML19345E964
| ML19345E964 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/25/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19345E953 | List: |
| References | |
| 50-320-80-11, NUDOCS 8102060476 | |
| Download: ML19345E964 (4) | |
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O APPENDIX A NOTICE OF VIOLATION Metrcpolitan Edison Company Docket No. 50-320 Based on the results of an NRC inspection conducted on June 1 -
July 5,1980, it appears that certain of your activities were not conducted in full compliance with the conditions of your NRC facility license No. DPR-73 as indicated below.
Items A, B and C are categorized as Infractions.
Ittms D and E are categorized as Deficiencies.
A.
The Order for Modification of Lictnse, dated July 20, 1979, as amendeu oy the Order dated February 11, 1980, states in part:
...Pending further amendment of the Facility Operating License, the licensee shall maintain the facility in accordance with the requirements set forth in Attachment 1...."
(Proposed Technical Specifications, Appendix A to Licensee No. DPR-73).
The proposed Technical Specification 6.8.1.g states in part:
" Written procedures shall be... implemented... covering... REC 0VERY F0DE procedures which involve a reduction in the margin of safety including those which...could cause the magnitude of radiological releases to exceed limits established by the NRC...." Special operating procedure S0P R-2-80-40, dated June 25, 1980, Dry Run of the Procedure for Reactor Building Atmosphere Cleanup using the Modified Hydrogen Control System and the "B" Train of the Modified Reactor Building Purge System; and operating procedure OP 2104-4.82, Revision 0, June 25, 1980, Reactor Building Atmosphere Cleanup Using the Modified Hydrogen Control System and the "B" Train of the Modified Reactor Building Purge System, require in part specific valve alignments as noted below to support various evolutions associated with purging the reactor building atmosphere.
Contrary to the above, 50P R-2-80-40 and OP 2104-4.82, were not implemented as follows:
during(the implementation of S0P R-2-80-40, On June 25, 1980, FS-V422B, 4238 and 424B) for the manual isolation valves reactor building ventilation and hydrogen control exhaust filter fire protection system were in the shut position.
This was contrary to S0P R-2-80-40, pre-requisite 4.25 which required that these valves be open by reference to the Fire Protection System Operating Procedure (2104-6.1).
1 July 1,1980, for approximately 20 minutes, AH-V3A, Con-
.ainment Isolation Valve for the Modified Hydrogen Control (MHC) System, was left open on a " temporary shutdown" of the system. This was contrary to OP 2104-4.82 paragraph 5.4.2 which required that this valve be shut on a " temporary shut-down" of the MHC System.
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Appendix A 2
On July 3,1980, for approximately two hours, AH-V38, Contain-ment Isolation Valve for Modified Hydrogen Control (MHC)
System was left shut on startup of the MHC System.
This was contrary to OP 2104-4.82, paragraph 5.2.10 which required that this valve be open to provide a return path for reactor building make-up air.
This resulted in an unscheduled shutdown of the system due to reactor building pressure reaching a procedural low limit.
B.
The Order for Modification of License, dated July 20, 1979, as amended by the Order dated February 11, 1980, states in part:
...Pending further amendment of the Facility Operating License, the licensee shall maintain the facility in accordance with the requirements set forth in Attachment 1...."
(Proposed Technical Specification, Appendix A to License No. DPR-73). The proposed Technical Specification 6.8.1.a states in part:
" Written pro--
cedures shall be... implemented covering...the applicable procedures recommended in Appendix 'Y of Regulatory Guide 1.33, Revision 2, February 1978.... " Appenjix ' A' of Regulatory Guide 1.33 lists procedures for performing maintenance.
Station Administrative Procedure 1026, Revision 11, November 16, 1979, Corrective Maintenance and Machinery History, implements maintenance control requirements for safety related equipment through the use of a " Work Request" form.
Contrary to the above on June 29, 1980,- the licensee wc-ked on the Modified Hydrogen Control System exhaust fan while it was exhausting the reactor building atmosphere and no " Work Request" form was completed.
During the evolution the individual caused the fan to trip (automatic shutdown).
C.
The Order of Modification of License, dated July 20, 1979, as amended by the Order, dated February 11, 1980, states in part:
"...Per. ding further amendment of the Facility Operating License, the licensee shall maintain the facility in accordance with-the requirements set forth in Attachment 1...."
(Proposed Technical Specification, Appendix A to License No. DPR-73).
The proposed Technical Specification 6.8.1.f requires in part:
" Written pro-l cedures shall be... implemented...cevering... Radiation Protection Plan implementation. Unit 2 Health Physics Procedure 1682, Revision 4, t
June 13, 1980, Control of Contaminated Tools, Equipment, and Material, paragraph 5.1.1 states:
" Tools, equipment and material used in contaminated and radiation areas will be given uncenditional release to clean areas if all exposed and unexposed parts ang beta-gamma and less than 20 dpm/100 cm2 a(lpha), and the radiation level surfaces are free of contamination less than 500 dpm/100 cm
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i at 1 inch is less than 0.1 mr/hr."
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Appendix A 3
Contrary to the above, between June 20 and 26,1980, several items which had fixed or removable contamination in excess of the limits of Health Physics Procedure 1682 were given unconditional release to clean areas from a Unit 2 control point.
Maximum removable contamination exceeded 10,000 dpm/100 cm2 and maximum radiation level was 10 mrad /hr on one piece of pipe.
D.
The Order fcr Modification of License, dated July 20, 1979, as amended by the Order dated February 11, 1980, states in part:
...Pending further amendment of the Facility Operating License, the licensee shali maintain the facility in accordance with the requirements set forth in Attachment 1...."
(Proposed Technical Specifications, Appendix A to License No. DPR-73). The proposed Technical Specification 6.8.2 requires in part that each recovery mode procedure, which could cause the magnitude of radiological releases to exceed limits established by the NRC, "...shall be submitted to the NRC prior to implementation; these procedures and changes thereto, shall be subject to apprcval by the NRC prior to implementation...."
Contrary to the above, as of July 4,1980, a recovery mode procedure change (Revision 1 to OP 2104-4.82, Reactor Building Atmosphere Cleanup using the Modified Hydrogen Control System and the "B" Train of the Modified Reactor Building Purge System) was implemented for approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> without being submitted to the NRC prior to implementation. Therefore, this revision was not subject to approval by the NRC prior to implementation.
E.
10 CFR 19.ll(a)(4) states in part:
"Each licensee shall post current ccpies of...any notice of violation involving radiological working conditions... order issued pursuant to Subpart B of Part 2...
(10 CFR 2)...and any response from the licensee."
10 CFR 19.11(d) states in part:
Documents, notices, or forms posted pursuart to this section shall appear in a sufficient number of place: to permit individuals engaging in licensed activities to observe them on the way to or from any particular licensed activity location to which the docunent applies...."
10 CFR 19.ll(e) states in part:
Commission documents posted pursuant to (a)(4)...shall be posted within 2 working days after receipt of the documents from the Commission; the licensee's response, if any, shall be posted within 2 working days after dispatch by the licensee.
Such documents shall remain posted for a minimum of 5 working days or until action correcting the violation has been canpleted, whichever is later."
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Appendix A 4
Contrary to the above as of June 30, 1980, none of the orders issued pursuant to Subpart B of Part 2 (10 CFR 2) since July 20, 1979, were posted.
In addition, the Notices of Violation issued by the Office of Inspection and Enforcement (Region I), dated May 28, 1930, and by the Office of Inspection and Enforcement, dated October 25, 1979, were not posted in a sufficient number of places, that is, one (dated May 28,1980) was posted only on a bulletin board in the Unit 2 Control Room and the other (dated October 25,1979) was not posted in Unit 2.
These Notices of Violation involve certain uncorrected radiological working conditions. The Unit 2 control room bulletin board is not a normal access to radiological areas such as the auxiliary building.
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