ML20010H360

Notice of Violation from Insp on 810614-0729

ML20010H360
Person / Time
Site:	Three Mile Island
Issue date:	09/01/1981
From:	Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20010H357	List: IR 05000320/1981012 ML20010H356 ML20010H360
References
50-320-81-12, NUDOCS 8109240386
Download: ML20010H360 (5)

Text

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t APPENDIX A NOTICE OF VIOLATICd Metropolitan Edison Company Docket No. 50-?20 Three Mile Island Unit 2 License No. DPR-73 As a result of the inspection condumd on June 14 - July 29,1981, and i

in accordanci with the Interim Enforacent Policy, 45 FR 66754 (Octobe 1980), the following violations were identified.

A.

10 CFR 50, Appendix B, Criterion VI, states in part: dMeasures shall be established to control the issuance of documents such as... drawings, incitding changes thereto, which prescribe ali activities affecting quality. These measures shall assure that documents, including changes, are revied for adequacy and approved for relaase by authorized personnel and are distributed to and used at the location where the prescribed 7

activity is performed...." The NRC approved Quality Assurance Plan * (QAP), Revision 0, July 14,1980, Section 3.1.2, first paragitph f. states.in part: " TH I... drawing s...which presc ribe the perfonnance of activities important to safety shall...be distributed in a controlled manner to preclude the use of obsolete drawings...." Administrative Procedure (AP) 1001 (listed in Appendix B of 'he QAP as ar important to safety document), Revision _24, aune 11,1981, Document Control.

4 1, paragraph 5.1 requires in part that properly distributed drawings "...will be stamped controlled _ copy in red. Only drawings so stamped will be used for... operation and maintenance....., Any drawing not stamped ' controlled copy' will be considered uncontrolled and shall not be used for plant operation and. maintenance...."

Contrary to the above, uncontrolled drawings were posted in the plant and an uncontrolied drawing was used for operation of a system important to safety as noted below.

On June 2,1981, Revision.4. dated June 4,1981 and Revision 5, dated June 18, 1981 tc the same drawing JS 082080, Submermd Domineralizer System (SDS), were

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pnsted at the SDS pool area.

Revision 5 was marked j

"Information Only" in red, and Revision 4 was not marked.

l Revision 4 was. referenced by operators during a valve alignment for sampling evolution of radioactive water being transferred to the SDS Feed Tank.

j On July 2,19' 1' SDS Vessel Status Map, JS 042781, (not 8

dated) was marked " Records /Information Only-Not for Construction" in red and was posted at the SDS pool area.

• Sy letter dated March 20, 1981 from B. Snyder (NRC 1MI Program Office, NRR) to G. Hovey (General Public Utilities Nuclear Group), Approval of TMI-2 Recovery OuAMty Assuranca P1an.

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On Jaly 1, lEB1 drawing JRW 052080, dated October 12, 1979 Standby Pressute Contrcl (SPC) System was marked "Information Only" in red and was posted near the SPC operating panel in the control poem.

This is Severity Lev'el IV Violation _(Supplement I)

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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 Specifications, Appendix A co License No. DPR-73).

1.

The proposed Te'chnical Specification 6.8.1 states in part: " Written procedures shall be... implemented covering

... recovery mode implementation...which... alter. the distribution or processing of significant quantities of stored radioactivity...(ana)...could increase the likeli hood of failures in systems important to nuclear safety and radioactive. waste processing or storage...."

Operations Procedure (OP) 2104-8.0, Revision 1, July 9,1981, and Ptvision 0, June 28,1981, SDS (Submerged Dominarlizer

'/ stem) Operati.onal Guidelines, paragraph 3.11 states:

"The FHB (Fuel. Handling Building) truck bay door shall be closed at all times except when it is required to be opensd for movement of materials / equipment in or out of the Fuel Handling Building." OP 2104-8.15, Revision 0, l

July 9,1981, SDS Submerged Ion Exchange (IX) System Operation Using IX 1A or IX 1 A and 18 only, paragraph 3.4 requires in part that SDS pool area radiation monitor CN-RIT-IX-03 bq operational as a prerequisite for SDS operations.

i Contrary to the above, the procedures were not properly implemented ir that:

y On June '35,1981 as of approximately 10:00 PM the l

FHB truck, bay door was not closed and no material /

l equipment. movement was in progress through that door i

entrance..

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On July 16,1981 as of approximaMly 2:00 AM the SDS pool area radiation monitor, CN-RIT-IX-03, was l

removed from service during the processing of l

radioactive waste through SDS to troubleshoot spurious alarms by another monitor (SDS Off Gas System proce." monitor, CN-RI-VA-06).

This is Severity Level IV Violation _(Supplement I) r l

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'NRC FORM 318 ( IO-8C ) NRCM O24

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The proposed Technical Specifications (TS) 5.8.2 and j

6.8.3.1 require in part that changes / temporary changes to procedures affecting radwaste processing / storage may be made provided they are properly reviewed by a Senior Reactor Operator, Management Staff, the Plant Operations Review Committee and/or approved by the Manager Site Operations, dependinq on the type of change. Admin-1strative Procedure L001, Revision 24, &ne 11,1981.

Document Control, establishes controls and implements these Technical. Specifications for changes (revisions) and temporary changes to procedures through the required use of fonas 1001-3 and 1001-5 Procedure Change Request form and Temporary Change Notice form, respectively.

Contrary to the above, forms 1001-3 and 1001-5 were not used to change procedures in that:

4 On June '30,1980 at 11:27 PM an entry in the Shift Foreman Log indicated a deviation from OP 2104-4.123, paragraph 4.1.4 which required observation of flow rate on recorder WDL-FR-3117 during the transfer of water from the Reactor Coolant Bleed. Tank to the SDS Feed Tanks.

Flow rate was verified by another indication since WDL-FR-3117 was out of service.

The procedure was not formally changed at that time.

On July 1[ 1981 at 8:00 PM an entry in the Shift Foreman Log indicated a deviation from 0" 2104-4.123, paragraph.4.1.6 which rcquired that level and 4

pressure for the Reactor Coolant Bleed Tank ("B")

were to be controlled from the radweste panel. Tank level and pressure control was shifted to the control room due to manpower consideratio9s. The procedure was not formally changed at that time.

This is Severit'y Level V Violation (Supplement I)

C.

10 CFR 50, Appendix 'B, Criterion VI, states in part: " Measures shall be established to control the issuance of documents such i

as instructions, procedures... including changes thereto, which prescribe all activities affecting quality. These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed,to and used at tl.e location where the prescribed activity.is performed...." The NRC approved licensee Quality Assurance Plen (QAP), Revision 0, Aly 14,1980, Section 3.1.2, first paragraph f, states in part: "THI procedures, instructions...which prescribe the perfonsance of activities important to safety shall...be distributed in a controlled manner to preclude the use of obsolete documents...."

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O F. F I C I A L.

R E C O R D C O P Y

Administrative Procedure (AP) 1001 (listed in ApF' Ax B to the QAP as an important to safety doctment), RF wn 24, June 11,1981, Document Control, paragraph 3."

states in part: "... procedures which are nuclear safe, related, involve radiatten exposure to personnel or involve potential or actual release of radiosctivity will be reviewed by the Plant Operations Review C.xamittee (PORC), and appmved by the Unit Superintendent (Director Site Operations)." further, paragraph 3.4 states in part: "All procedures distributed...are considered controlled and stamped with a red ' Controlled Copy' stamp at the time of distribution.

Controlled procedures only are to be used for maintenance and operation of the plant."

Contrary to the aboie, htween June 30 and July 2,1981 uncontrolled instructions and procedures were posted or used around the Submerged Dominard.lizer Zystem (SDS) pool area as noted below.

Various copies'of a handwritten PING (Particulate Iodine, Noble Gas) Monitor Operations Procedure at the SDS, Off Gas System PING mcnitor, were posted and were at the operator's desL This procedure was not PORC reviewed, was not approved by the Director Site Operations, and was not marked " controlled copy".

Table 1.5.1.3,' Calculated Voluee vs. Liquid Level - Waste Storage Tanks (WG-T-2A/28/2C/2D) Upper Tanks, to OP 2104-4.50, Fuel Pool Waste Storage Systen, was posted on the east wall of the Fuel Handling Building (FHB) near the tuk level manometer, and Heise gage indicator. Revision S tas posted while Revision 4, dated January 4,1980 was the effective table. The pusted table was not marked " controlled copy".

Two different gage correlations (gallons vs. inches) for WG-LI-1A (SDS Feed Tank l Level Indicator) were posted at the SDS Feed Pump contriol panel and at the operators desk. Both tables applied to the same gage. Neither correlation was marked controlled copy".

OP 2104-8.4, Revision O', May 1,1981, SDS Monitor Tank, was distributed for use in the plant without review and approval by NRC onsite staff as required by Technical i

Specifications.

This is Severity l'evel V Violation (Supplement I) l l

L*"? ! "* "- '" ' """ *"- -.-.-. O F FI C,I A L R. E C O R D C O PY- _ _ -._

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Pursuant to the provisions of;10 CFR 2.201, Metropolitan Edir.on Company is hereby required to submit to this office within twenty days of the date of this Notice, a written statement or explanation in reply, including: (1) the correct 1' e steps which have been taken and the results achieved; (2) correc?.tve steps which will be taken to avoid, further violations; and (3) tne date when full compliance will be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation. Where good cause is shown, consideration will he given to extending your response time.

The responses directed by this hotice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Redaction Act of 1930, PL 96-511.

"hf Dated R. fi. I.e.imig, Chief v

Projects Branch #2, Division of Resident and Project Inspect. ion I

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'""C" OFFICIAL RECORD COP (

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