ML20003G402
| ML20003G402 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/20/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20003G397 | List: |
| References | |
| 50-289-80-21, NUDOCS 8104290321 | |
| Download: ML20003G402 (3) | |
Text
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Ah APPENDIX A NOTICE OF VIOLATION Metropolitan Edison Company Docket No. 50-289 Based on the results of an inspection conducted by the NRC's Perfomance Appraisal Branch on July 7-11, 14-18, 27-31 and August 1,1980, it appears that certain of your activities were not conducted in full compliance with ccWitions of your NRC Facility License No. DPR-50 as indicated below.
Items A, D and F are infractions.
Items B, C and E are deficiencies.
A.
Technical Specification 6.5.1.6, "PORC-RESPONSIBILITIES" states, in part, "The Plant Operations Review Committee shall be responsible for...e.1) Review of reportable occurrences under Section 6.6 and any violations of these Technical Specifications or Operating License DPR-50, including a report... covering evaluation and recomendations to prevent recurrence, and 2) Review of violations of applicable federal statutes, codes, regulations and internal station procedures and instructions having nuclear safety significance."
Technical Specification 6.5.1.7, TORC-AUTHORITY" states, in part, "The Plant Operations Review Comittee shall...b....at all times for 6.5.1.6(e), render deteminations with regard to whether or not each item considered constitutes an unreviewed safety question."
Contrary to the above:
1.
During the approximate period of the past twelve months for which records were exatined, tne Plant Operations Review Comittee did not review and report their evaluation and recommendations for violations of Technical Specifications or review violations of internal station procedures having nuclear safety significance as reported in Quality Assurance I
audit reports.
The PORC did not review these audit reports or their findings.
Nearly every QA audit report examined contained findings which constituted violations of Technical Specifications and/or internal station procedures.
Examples of these findings are contained in QA audit reports 0-lNI-80-01 Finding 4. S-TMI-80-3 Findings 3 and 7, and S-TMI-80-08 Finding 11.
2.
During the approximate period of the past twelve months for which records were examined, the PORC did not render deteminations with regard to whether or not items considered under Technical Specification 6.5.1.6(e), including reportable occurrences, violations of Technical Specifications and violations of internal station procedures, constituted an unreviewed safety question.
8104200..
Appendix A 2
B.
Technical Specification 6.5.1, " Plant Operations Review Committee (PORC)," Section 6.5.1.5, " Quorum," states, "A quorum shall consist of four members, at least one of whom shall be either the Chairman or Vice Chairman of the Committee. A quorum shall not take credit for more than one alternate member."
Contrary to the above, during PORC meetings 80-06 and 80-11, the quorun took credit for two alternate members.
C.
Technical Specifica'ian 6.5.2. A.2, " MET-ED CORPORATE TECHNICAL SUPPORT STAFF-RESP 0hsIBILITY," states, in part, "In its concern with the more detailed issues (rather than the broad issues) of nuclear safety, it shall be the responsibility-of the Met-Ed Corporate Technical Support Staff to...d. Review of proposed changes to these Techw; cal Specifications and Operating License DPR-50.
f.
Review of reportable occurrences, and violations of these Technical Specifications and Operating License DPR-50."
Contrary to the above, following the March 28, 1979, THI-2 accident, the Met-Ed Corporate Technical Support Staff (MECTSS) was disbanded.
Although many MECTSS responsibilities were subsequently performed by various organizational units of the GPU Service Corporation staff, the MECTSS review responsibilities had not been assumed in writing by any other organizational unit for:
(1) the review of proposed changes to the Technical Specifications and Operating License DPR-50, and (2) the review of reportable cccurrences, other than those requiring twenty-four hour written notification to the NRC.
D.
Technical Specification 6.5.2.3.1, "GEHERAL OFFICE REVIEW BOARD (G0RB)-FUNCTION," states, "In its concern with the broader issues (rather than the detailed issues) of nuclear safety, it shall be the primary responsibility of the General Office Review Board to...a. Foresee potentially significant nuclear and radiation safety problems and to recommend to the President of Met-Ed how t
they may be avoided.
- b. Periodically review the Generation Division audit program to assure that audits are being accomplished in accordance with requirements of Technical Specifications and ANSI 18.7-1972 Standard for Administrative Controls for Nuclear Power Plants."
Technical Specification 6.5.2.B.7, "GORB-REVIEW," states, in part, "The General Office Review Board shall review as is consistent with its responsibilities...c. Proposed changes in and violations of these Technical Specifications or Operating License DPR-50."
Appendix A 3
Contrary to the above, during the period April 1,1979, to June 30, 1980,-
the GORB did not review violations of Technical Specifications or Operating License DPR-50 as reported in Quality Assurance audit reports.
The GORB QA Audit Subcomittee did review audit reports; however, their report on audits for the period April 1,1979, to June 30,1979, was only a statistical sununary of open audit findings.
It did not address the subject of any individual audit report or audit finding, which described violations of Technical Specifications.
E.
Code of Federal Regulations, Title 10. Part 50.59(b) states, in part, "...The licensee shall furnish to the appropriate NRC Regional Office... annually...a report containing a brief description of such changes, tests, and experiments," (made pursuant to 10 CFR 50.59(a)]
-including a sumary of the safety evaluation of each."
Contrary to the above, as of August 1,1980, changes made pursuant to 10 CFR 50.59(a) during calendar years 1978 and 1979 were not reported to the NRC.
The last resort of 10 CFR 50.59(a) changes was made on April 25,1978, for c1anges made during 1977.
F.
Technical Specification 3.18.4.1 states,. "The CO2 system for the Cable Spreading Room shall be operable with a minimum level corresponding to 8500 lbm and a minimum pressure of 300 psig in the associated storage tank (s)."
Technical Specification 3.18.4.2 states, in part, "With the CO2 system for the Cable Spreading Room inoperable:
a.
Establish a continuous fire watch with backup fire suppression equipment for the unprotected area within one hour." These requirements are applicable at all times when the equipment in the area is required to be operable.
Contrary to the above, on December 31, 1979, while maintaining the plant in cold shutdown, the CO2 system for the Cable Spreading Room was noted by plant personnel to be below the 8500 lbm minimum level. A fire watch was establisned within one hour but was not continuously maintained prior to restoring the system to an o)erable condition.
The fire watch was secured when PORC determined tlat no equipment in the Cable Spreading Room was required by the Technica?
Specifications to be operable, and that no fire protection m needed. The PORC determination was in error, because eq11pment (instrument, control and power cables) in the Cable Spreading Room is required to be operable to monitor RCS pressure and temperature, within the limits of T.S. 3.1.2, and to maintain the plant in cold shutdown, although specific equipment operability requirements are not delineated by Technical Specifications.
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