ML20003A735
| ML20003A735 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/05/1980 |
| From: | Herbein J Metropolitan Edison Co |
| To: | Grier B NRC Office of Inspection & Enforcement (IE Region I) |
| Shared Package | |
| ML20003A727 | List: |
| References | |
| TLL-221, NUDOCS 8102050814 | |
| Download: ML20003A735 (10) | |
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Metropolitan Edison Company Post Office Box 480 I
Middletown, Pennsytvania 17057 717 944-4041 Writer's Direct 0 41 Number May 5, 1980 TLL 221 Office of Inspection and Enforcement Attn:
B. H. Grie*, Director Region I U. S. Nuclear Regultory Corniasion 631 Park Avenue King of Prussia, Pa.
19406
Dear Sir:
Three Mile Island Nuclear Station, Units I and II (TMI-l & TMI-2)
Operating License Nos. DPR-50 and DPR-73 Docket Nos. 50-289 and 50-320 Inspe tion Report Nos. 50-289/79-23 and 50-320/79-28 Enclosed please find our responses to Inspection Report Nos. 50-289/79-23 and 50-320/79-28.
For yot r convenience, the alleged infraction, or a su= nary thereof, precedes each response.
Sincerely, t
J. G. Herbein Vice President TMI-I JGH:WCR: sal Enclosure cc:
J. T. Collins 830 Metropohtan Ed sen Company is a Member of the General Pubic Ut:I;t:es System
Ih6 Notice of Violation Infraction A Section 4.4.a and Table 3 of the Unit 1 Environmental Technical Speci-fications (ETS) and Section 3.2 and Table 3.2-2 of the Unit 2 ETS require, in part, that specified nu=bers of samples of air particulates and air iodines be collected and analyzed on a weekly basis.
INF. A (1) and (2). Contrary to these requirements several air particulate samples and several air iodine samples were not collected and analyzed.
Thus fewer than the required number of each were performed for the specified time interval.
Response A The IMI Environmental lepact Assessment (TMI/EIA) Group was developed to strengthen our control system by insuring the effectiveness of our environ-mental operating procedures.
The responsibility of this Group, in part, is to develop mechanisms that will eliminate or at least minimize incidents such as those resulting in Infraction A.
The TMI/EIA Group presently is staffed with nine professionals with approval to expand to twelve environmental scientists.
They are responsible for both off-site radiological and nonradiological environmental surveillance and assessment and provide the " hands-on" control neces.ary to insure the responsive and effective implementation of environ-mental programs.
The TMI/EIA Group has inplemented the following controls to prevent the reoccurrence of Infraction A:
1.
Additional air sampling equipment has been purchased and is avail-able to replaca equipment that requires an extended period of time for repair.
2.
The TMI/EIA Group performs surveillance checks en the air sampling equipment midway during the sampling period to identify any malfunctions.
3.
The notification process has been improved to expedite the repair of field equipment needing service.
Infraction B Section 4.4.c and Table 3 of the Unit 1 ETS and Section 3.2 and Table 3.2-3 of the Unit 2 ETS require, in part, that all samples be analyzed with sufficient sensitivities to meet the minimum specified analytical sensitivi-ties.
INT. B (1) and (2). Contrary to these requirements, air samples and drinking water samples at specified locations and times were not analyzed with sufficient sensitivity for I-131.
Response i The TMI/EIA Croup has notified their ce==ercial laboratories to perform analyses at the required sensitivitie:-
Additionally, the implementation of the TMI/EIA Croup REMP data management system, includes the review of labora-tory results for analytical sensitivity.
Also, laboratory complfance with analytical sensitivity requirements is verified through periodic audits.
Infraction C Section 4.4.a and Table 3 of the Unit 1 ETS require, in part, that milk sa=ples be collected and analyzed from four indicator and one background station at monthly intervals during the grazing season.
Secticn 3.2 and Table 3.2-2 of the Unit 2 ETS require, in part, that milk samples be collected and analyzed frc= three indicator and one background station at semi-monthly intervals during the grazing season and monthly at all other times.
Contrary to these requirements, = ilk samples were not always collected and analyzed at the required frequencies or locations.
This resulted in fewer than the required nurtber of milk samples being collected and analyzed during these time interva'.s.
Response C These sampling activities are now under the direct surveillance of the TMI/EIA Group.
Internal auditing procedures are in practice that periodically review sampling procedures, techniques, and frequencies.
Infraction D Section 4.4.a and Table 3 of the Unit 1 ETS and Section 3.2 and Table 3.2-2 of the Unit 2 E_3 require, in part, that water samples be collected at the City of Colu=bia at the specified frequencies and the specified analyses be perfor=ed.
Contrary to these requirements, water samples from the City of Columbia were not collected and analyzed at the specified frequency during the first quarter of 1978.
This resulted in fewer than the required number of samples being collected and analyzed during this time interval.
Response D In addition to the response for Corrective Action C (above), additional water sampling equipment has been purchased and is available to replace equip-ment that requires an extended period of time for repair. Also, the notification
s process has been improved to expedite the repair of field equipment needing service.
Infraction E Section 5.3 of the TMI Units 1 and 2 ETS requires, in part, that inde-pendent audit and review functions for environmental matters will be performed under the direction and control of the Manager-Generation Engineering.
These audits and reviews will encompass, among other t'.ings, the results of the Environmental Monitoring Programs prior to their submittal in each Annual Environmental Monitoring Report.
Contrary to these cequirements, the results of the Environmental Monitor-ing Pregrams reported to the NRC in the 1978 Annual Environmental Monitoring Reports were not audited.
Response E Independent reviews and audits are performed on the Environmental Monitor-ing Progra=s by the TMI/EIA Group which reports to the Director - Environment, Health, and Safety.
In addition, an independent audit also is performed by the Quality Assurance Group.
~3 Infraction F Section 5.5 of the Unit 1 and Unit 2 ETS requires, in part, that detailed written procedures, including applicable checklists and instrnctions, shall be prepared and followed to implement the environcental technical specifications.
Procedures shall include sampling, data recording and storago, instrument calibration, measurements and analyses, and actions to be taken when limits are exceeded.
INF. F (1). Section 2.2 of the Unit 1 ETS requires, in part, that the pH of the contents of each tank of neutralized regenerate wastes be determined prior to-release and adjusted to specification, if necessary. Additionally, as a minimum, the pH of a sample is taken from the plant river _ vater discharge during the release of each tank of regenerate wastes, or at weekly intervals.
Contrary to these requirements, as of the tates of inspection, the regenerate neutralizing tank and the plant river water discharge sampling procedures were not prepared as required (Unit 1).
Response F (1)
OP1104-18 and SP1301-9.10 do cover all the ETS requirements for sampling and analysis of water from the regenerate neutralization tank and plant river water discharge. Assuming that the inspectors nonccmpliance Item 79-23-11 was initiated to note a lack of detail for obtaining these samples, a generic samp-ling procedure will be written by June 1, 1980, to provide such detail.
INE.F (2). Section 2.1.6 of the Unit 1 ETS requires, in part, that if the Unit 1 Control Room AT chart recorder is out cf service, the plant inlet and discharge temperatures be obtained from the record.rs located in the mechanical draft cooling towers (MDCT).
Sections 5.5.1 and 5.5.2 of the Unit 1 ETS require, in part, that detailed written procedures be prepared and followed to ensure compliance with the Limiting Conditions for Operation, Section 2 of the ETS, including procedures to be followed in the event that the Unit 1 Control Room plant AT chart recorder is out of service.
Contrary to these requirements, as of the dates of this inspection, written procedures detailing actions to be taken when the Control Room AT recorder is out of service were not prepared and followed as required.
Response F (2)
" Mechanical Draft Cooling Tower Operation" (OP1104-37 Rev. 11), to which the NRC refers, contains the following provisions for implementing the Unit 1 ETS, LCO Section 2.1.a:
Procedure Section 37.3.4 Emergency System Operatien - Step 37.3.4 " Operation when normal te=perature indication not available":
1.
When normal river water AT indications are unavailable, calculate AT at least once per hour using available indication of inlet and outlet river water temperatures.
Enter the calculated value in the CR0 log.
Our contention is and has been that this guidance is adequate. However, to resolve the concern of the NRC, a PCR will be submitted to OP1104-37 to provide additional guidance on emergency system operation.
INF. F (3). Section 3.1.1.a of the Unit 2 ETS requires, in part, that during normal operations, the contents of the holding tanks for the demineralizer and condensate polisher regeneration solutions shall be sampled prior to being discharged and the pH measured in accordance with the procedures prepared by the licensee per Section 5.5.
Contrary to these requirements, as of the dates of this inspection, proce-dures for sampling the holding tanks for desaneralizer and condensate polisher regeneration were not prepared and followed as required.
Response F (3)
OP2104-2.11 does cover all the ETS requirements for sampling and analysis of water from the holding tanks for demineralizer and condensate polisher regen-eration solutions. Assuming that this infraction was initiated to note a lack of detail for obtaining these samples, a generic sampling procedure will be written by June 1, 1980, to provide such detail.
Infraction G Section 5.5 of the ETS for TMI Units 1 and 2 requires that, " Detailed written procedures, including applicable checklists and instruccions, shall be prepared and followed to implement the environmental technical spicifications.
Procedures shall include sampling, data recording and storage, instrument cali-bration, measurements and analyses, and actions to be taken when limits are exceeded."
INF.G (1). The Units 1 and 2 Radiological Environmental Monitoring Program (REMP)
Surveillance Procedure GP 1402, Rev. O, dated November 15, 1977, requires in part, that REMP Sample Collection Sheets be completed and distributed as specified in Appendix A of that procedure.
Contrary to these requirements, the REMP. Sample Collection Sheets described in the REMP Surveillance Procedure GP 1402, Rev. O, were not completed and distributed as required by Appendix A of the Procedure from April 1979 to the dates of inspection.
Response G (1)
I The Sample Collection Sheets for the time period contended are on file in the office of the TMI/EIA Group.
DUP.G (2). Unit 2 Operating Procedure No. 2104-2.11 requires that a release permit be completed for each neutralizing tank discharge, which is to include specified data at the start and termination of each tank. discharge.
Contrary to *.hese requirements, the neutralizing tank release permits were completed, as required, for Unit 2 neutralizing tank discharge on several not occasions, including on October 5, 1978, March 1, 2, 3, 4, 5, 6, 7, 8 and 10, 1979.
Response G (2)
A continuing effort is ut.t. rway to locate these release records. ' To date these records have not been located.
INF. C (3). Unit 1 Procedure No. IC39' requires annual calibration of the plant intake / discharge temperature monitoring system.
Contrary to these requirements, the plant intake / discharge temperature monitoring system was not calibrated during 1978 and 1979 as required.
INF. C (4). Unit 2 Procedure No. 2014-3.8, Rev. 6 assigns to Unit 1 the responsi-bility to assure compliance with plant AT requirements, including calibrations of the plant intake / discharge temperature mon.:orirg system.
Contrary to these requirements, Unit 2 Procedure 2104-3.8, Rev. 6 was not fully implemented in that the plant temperature monitoring system was not'cali-brated during 1978 and 1979.
Response G (3) and (4)
The calibration of the Station (combined Unit I and Unit 2) river water AT was not accomplished during 1978 or 1979 as set forth in FM Procedure IC-39.
The reason it was not performed was apparently due to lack of scheduling.
IC-39 The river water does not appear on the computer scheduling base as a PM Task.
AT instruments are on the computer base and are scheduled to be calibrated every two years per generic procedure IC-3.
This is identified as " Required Mainten-ance" and was initialized on the computer on February 20, 1980. The calibration of these instruments was completed on March 14, 1980.
To address this calibration requirement in the' future, we have made the following changes:
Procedure IC-39 has been re-written in Surveillance Procedura format and 1.
will be identified as Unit 1 Surveillance Procedure 1302-5.5, " Check /
Calibration of MDCT Temperature Loops".
It will be put on the com-puter base for scheduling on a Refueling Interval basis, the same as the Unit 2 Surveillance, 2322-R2. As a Surveillance, it will be scheduled on a fixed time interval and appropriately identified as a PM on a floating schedule.
These identification and scheduling changes will serve to preclude any further violations for noncompliance with this ETS requirement.
Infraction H Section 3.1.2a(1) (c) of the Unit 2 ETS requires that ichthyofauna be sampled to establish population estimates in specific areas and to detect and assess the significance of changes in species composition, relative abundance, seasonal and spatial distribution, condition, and diversity of species as related to TMINS operation... This monitoring program shall commence at initial attainment of normal' operation of Unit 2 and continue for a period of at least three years.
Contrary to the above, the required fish studies were not' performed during the period from April 1, 1979 through November 26, 1979.
Response H For corrective / preventive action refer to our letter of December 21, 1979 (LER 79-020/03L-0).
Infraction I Section 5.7.1 of the Unit 1 ETS requires in part, that records demonstrat-ing compliance with the Limiting-Conditions for Operation in Section 2 of the ETS, including plant AT records, be retained for the life.of the-plant.
Contrary to this requirement, records of AT measurements were not retained for February 19, 1979.
Section 5.8.6 of the Unit 2 ETS requires, in part, that records of all data from environmental monitoring, surveillance and study activities required by these ETS shall be made and retained throughout the term of the operating license.
Contrary to this requirement, records of plant AT, influent and effluent temperatures, monitoring required by the Unit 2 ETS, were not retained for March 20, 21, 22, 23 and 24, 1979, during which time the Unit 2 control room recorder was off-scala.
Response I Unit 1 - Review of the TMI-1 Station AT recorcer chart indicates that from about 5 PM to 12 PM February 19, 1979, the station AT recorder was experiencing difficulty in inking the chart paper.
During this seven hour period the station AT was recorded intermittently, with the inking problem completely resolved by 2 AM on February 20, 1979.
Since this inking problem does not render the recorder inoperable with respect to monitoring the plant discharge, and since other plant records are available to verify and document the station AT during the seven hour period, we do not consider this recorder inking problem to be an infraction.
Unit 2 - A continuing effort is underway to locate these records. To date they have not been located.
Infraction J Section 3.1.1 of the ETS, Unit 2, requires, in part, that a nonroutine report, as specified in subsection 5.6.2.b, shall be made if the thermal characteristics of the discharge from outfall serial number 001 fail to comply with relevant limitations prescribed by the Commor _sith of Pennsylvania and the U.S. Environmental Protection Agency in the et ficates and permits issued to the licensee pursuant to the provision of Sect
.-n 401 and 402 of PL 92-5Cb, as cited in Secticn 5.4 of the ETS.
Contrary ~.. these requirements, on March 14, 1979, between 11:45 AM and 0
12:40 PM, the station AT exceeded 12 F, the specified thermal discharge AT limit, and this occurrence was not reported to the NRC.
Response J To date, our investigation of this incident is incomplete.
_a_
j Infraction K Section 2.1 of the TMI Unit 1, ETS, Limiting Conditions for Operation requires, in part, that during the period between October 1 and March 31, the 0
plant discharge temperatures be no greater than 12 F above inlet temperature.
4 Contrary to these requirements, on December 4, 1978, the plant discharge temperature was greater than 12 F above the plant inlet temperature.
i 5
Response K Refer to the December 4, 1978, License Eveat Report 78-31/4T which speci-fies:
(1) the corrective action taken to remedy the immediate problem; (2) the corrective action taken to avoid future occurrences; and (3) the date in which full compliance was achieved.
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THI - I & TMI II BCC LIST Mrs. Pat Higgins Mr. S. H. Duerson Edison Electric Institute Babcock & Wilcox 1111 19th ctreet, NW P.O.' Box 1260-i Washington, D.C.
20036 Lyncnhurg, VA 24505 Mr. E. L. Blake, Jr.
Mr. T. F. Hartley, Jr.
Shaw, Pittman, Potts & Trowbridge Marsh & McLennan, Inc.
1800 "M" Street, NW 1221 Avenue of the Americas Washington, D.C.
20036 New York,_NY 10020 Mr. R. Sanacore
.Mr. A. S. Dam-American Nuclear Insurers Burns & Roe, Inc.
The Exchange - Suite 245 650 Winters Avenue 270 Farmington Avenue Paramus, NJ 07652-Fannington, CT 06032 2
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P. Clark - GPUSC - Parsippany Ms. Margaret Reilly R.'loole - TMI-I Supervisor Chief Div. of Rear. tor Review R.'W..Heward - TMI Trl. 180 PA Department of Environmental Resources J. C. DeVine --TMI Trl. 110.
.Fulton Bank Building J. G. Herbein - TMI1Trl.118 Harrisburg. PA 17120 W. N. Moreau - TMI Trl. 22~
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J. T. Collins - NRC Trl.'l q) g;egge Toir-en pcs Lear '
E. G. WallaceL-Parsippany-Licensing
- 0. Hovey - TMI Trl. 105 R. F. Wilson - TMI Trl 105 R. Fenti - QA - TMI Trl. 22 D. H. Reppert -:TMI G0RB Secretary Parsip.
S.'D. Chaplin - THI Licensing C. E. Hartman - TMI-I PORC(Chairman - TMI-I J. J. Barton - TMI Trl. 102 M. A. : Shatto - TMI-I PORC ' Secretary'- TMI-I~
L. W. Harding - TMI Licensing-G. A. Aunder - TMI-II PORC Chairman - Trl 10 R. M. Klingaman - Met-Ed Reading-D. C. Carli-TMI-II PORC Secretary:- Trl.10 N. Kazanas - Parsippany - QA 1W. F. Schmauss - TMI-I: & :II:GRC Chairman -' 2 J. F. Wilson - THI Trl. 14 B. A. HockleyJ-Discovery Room'- Crawford St B. Ballard - TMI Trl.-16 R. L. Rider - Bechtel - TMI Trl. 173 G. P. Miller - TMI-I
'D. S'ith - Reading - Production Supervision.
R. C. Arnold - TMI Trl. 201 P. S. Walsh - GPil Parsippany D. G. Mitchell - Met-Ed Reading B. Elam - TMI Trir. #104 C. W. Smyth - Parsippany Licensing-J. Chwastyk - TMI - Ops-2
.M. J. Ross TMI - Ops-1=
R'. A. Lengel - Engineers #1 File:
02.0016.0001.0001.02
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