ML20024B242

Notice of Violation & Proposed Imposition of Civil Penalties in Amount of $155,000 from Investigation on 790328-0731

ML20024B242
Person / Time
Site:	Crane
Issue date:	10/31/1979
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20024B241	List: ML20024B240 ML20024B242
References
GPU-2316, NUDOCS 8307070482
Download: ML20024B242 (12)

Text

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4 APPENDIX A NOTICE OF VICLATION i

"e r:p:litan Ecison Company Docket No. 50-320 Tris refers to tne investigation conducted by an Office of Inspection and Enfer:emer: Investigation Team at the Tnree Mile Island Nuclear Generating j}zi{cn,Micdlet:wn, Pennsylvania,ofactivitiesauthorizedbyNRCLicenseNO.

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Su-ing ne inves-iga-icn concu::e: en March 25, 1979 througn July 31. 1979

'Inves-iga-icn N:. 50-220/75-10), tne following apparent items of noncem:liance e e i:en-ifie::

Te: nical 5:ecification 3/4.7.1. "Tur:ine Cycie " recuires in Se: ice 3.7.1.2, tha-nres ince:en:e..

steam cenera cr emercen v fee:-a er cum:!

anc associa ed flow patns snall be operaole curing, power' coerations, excect: if one emergency feecwater system is inoperable it must be restored to coerable status witnin 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the plant mus: ce in h Snutcoan witnin the nex 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Con:rary to the a:ove, for an uncetermined period ius prior to :ne

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rea:ter tri: at a: proximately 0400 nours on Maren 25, 1975, tne fio.

ca:ns t: Octn steam generators were mace inoceraole by feecwater neace-istia-ic. valve closure. (In acci:icn. on January 2, Fe:ruary 25 an:

Ma :n Zi,1975. tre fic- :a ns frem ali :nree emergen:;. feec e er cun:s we e simultaneously ma:e ine: era:le :. feecwater nea:s-iscia-icr vah i ci:sure curing ne ce-ferman:e cf. anc in accorcance wi n, an im:re:er sur.eiliance test prececure.)

inis violation contributec to an accident.

(Civil Penalty 55,000) 2.

Tne severity and uniqueness of the accident which occurred at Tnree Mile Island resulted in a marked reduction in the normal good health pnysics pra:tices wnien are mandated by the NRC Regulations.

Under the circum-s ances of an a:cident of this magnitude the NRC recognizes that in the interes; of reactor safety a ceparture from normal health physics practices an: stancarcs may sometimes be mandated by the exigencies that exist curing such conditions.

However, the NRC also believes that the licensee, witn the resources available and-taking into account the time frame aeailable for conduct of safety related functions, could have taken a:citional measures to cetter control the overall health physics actions anc cecisions wnich were mace curing the course of tne accicent.

ine f:llowing items of noncompliance exemplify unacceptable cegracation from nes'th :hysics practices pertaining to control of access to hign radiation areas, concuct of raciation surveys, and personnel radiation exposure c.'t: ring.

13 CFR 20.201, " Surveys," receires in Section (b) tna; each licensee s.all. eke :

cause : ce mace su:n surveys as may ce necessary to ccc:iy c..

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2-10 CFR 20.202, " Personnel M:nitoring," recuires tna; the licensee supply so repriate personnel c: nit ring equipment anc recuires its use for es:n incivicual wne enters a restrictec are: and ir likely to receive a cose in excess cf 25 per:ent f :ne a::licabie value specifie: in 10 CFR 20.101.

e:nnical Specifica:icn 5.12, "Hign Radiation Area," recuires tna; eacn T

area in wni:h tne intensity of raciation is greater tnan 1000 mre /nr be cr:vided with locke: co rs

prevent unautnori:ed entry into tne area an: tna; any incivicual enterin; tne area be ecuipped witn a continuously incicating ccse ra e c:-it: ring cevice.

12 C.:R 20.123, "Ex::sure cf indivicuals to concentre-ions of radica:-ive cater'ais in air in restric ec areas," re uires in Se:-i:n (a)(3) tna:

9s licensee ca<e sui a:ie ceasurements cf tne ccncen ra-ions of ra:ic-a:-ise ma eria'.s in air f r ce a: ting anc evalua-ing air: rne ra:ica:-ivity i

res ricted areas for tne rur:cses of ceterminin:

regulatien in 10 CFR 20.103(a)(1).

~ ccm:liance witn ne 10 CFR 20.1C1, "Ex::sure cf individuals to radiation in restricted areas,"

recuires tne; no licensee possess, use or transfer licensec material in sucn a renne as :: cause any incivicual in a res ricte: area to receive in any peric: of ore calencar cuarter a c:se in excess cf tnree rem to tne wncie cec, c-15 3/; rer :: :ne nan:s anc forearr.5, er 7 1/2 rer :: tne ssin cf tne wnoie :::..

C:n rary :: :ne a:cve:

r:: 100 n:urs en Mar:- 25, 1979 un-il tne aftern::n of Mar:n 3;. 197,

tne cc:rs to tne auxiliary cuiicing were nc; 10:Kec an: access was nc-otnerwise contro11e: even tnougn tne builcing was known to ce a hign radiation area with raciation levels muen greater than 1000 mrem /nr curing tnis ceriod; B.

From the evening of Mar:n Pa. 1979 until the evening of Maren 29, l

1979, at least two entries into the auxiliary building were mace ey l

individuals who were not ecuipped with a radiation monitoring device which continuously incicated tne dose rate; C.

f.o measurements were made of the concentrations of aircorne radioactive materials in the Unit 2 auxiliary building for periods during which indivicuals were excosed frem 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> on March 28, 1979 through l

midnign: March 30, 1979, nor in the Unit 1 nuclear sample room anc primary cnemistry laboratory for periods during whicn indivicuals l

were exoosed f rom O'00 nours on March 28 througn 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> on

! arch 30, 1979; D.

On March 29, 1979, an Auxiliary Goerater was oe mitted to enter areas cf the auxiiiary cuilcing wnere exac ure rates of u: to 100 R!nr existe:.

Raciation surve,. inicrmetion anc approcriate personcei monitoring were

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not provided to the operator for this entry.

This contributed to the operater receiving a whole booy dose of 3.170 rems.

Wnen this dose was acced to the operator's previous dose for the quarter, the operator's quarterly wnole bocy dose was 3.870 rems as measured by personnel dosimetry devices; E.

On March 29, 1979, a Nuclear Engineer entered an area of the auxiliary building where the' radiation level was greater than tnat which coulc ce measured by his portable survey instrument (2R/hr).

Failure to cerform a survey of the ex:osure rate in this area contributed to tne indivicual receiving a wnole body cose cf 3.14 rems for this entry.

Wnen tnis cose was ad:ed te tne engineer's previous cose for tne quarter, tne engineer's i

cuar erly wnole b::y cose was 4.175 rems as measurec Oy cersonna cesime ry cevices; F.

On Mar:h 29, 1979, a Chemis ry Foreman was permit e: :: receste:12 enter high radiation areas and handle samples of highly racicactive reactor ecolant.

This contributed to the Foreman receiving a wnale ocoy dose of 4.100 rems.

Wnen tnis cose was adoed to the Foreman's orevicus d:se for tne cuarter, tne Foreman's quarterly wnole cocy cose was 4.115 rems as measured by cersonnel dosimetry devices; G.

On Mar:h 29, 1979, a Chemistry Foreman anc a Racia-ion Prote:-icn Fo eman were cer-itte: to nancie a nigniy racica::ive rea: cr c::iant sam:le witneut acecuate oersonnei monitorinc anc wi n::: firs ce--

forming a surve;. cf nan: and ferearr ex:csuhe rates.

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sam ie resci e: in a :al:ula e: c:se te ne nan =3 an: forearms cf ins Cnemistry Foreman of accu-147 rems anc a calculate: cose :

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and forearms of the Raciation Protection Foreman in tne range of 44 to 54 rems; and H.

On March 25, 1979 anc March 29, 1979, several individuals received skin contamination of the hand and other parts of the body sufficient to cause exoosure rates in tne range of 20-100 mR/hr when measured with a hand-held survey instrument and no evaluation of the dose to the skin of these individuals was made.

Each day constitutes a separate violation, [ March 2S (A, 5, C, and H),

March 29 (A, B, C, 0, E, F, G, and H), and March 30 (A and C)]; a civil penalty of 55,000 is imposed for each.

(Cumulative Civil Penalty 515,000) 3.

Technical Soecification 5.5.1, " Plant Operations Review Cc=mittee,"

recuires: in Se: tion 6.5.1.6.a, that the Plant Operations Review Committee (PORC) review all procedures (and changes thereto) required by Technical Sce:ification 6.6 and any othcr procedure (or change) cetermined to affect nu:iear safety.

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.a-Centrary t: tne above, inadequate reviews were performed on betn Procedure Cnange Re:uest No. 2-78-707, Revision 4 to Surveillance Procedure 2303-M27A/5, anc Procedure Change Recuest No. 2-73-595, Revision 8 :: Surveillan:e Procecure 2303-M14A/5/C/D/E; both were reviewed an: approved by the PORC (November 9,1978 and August 15, 1978 res:ectively).

Ea:h a:;reved :hange in:luded a valve lineup which resulte: in erzergency feecwater header isolation, contrary to Technical See:ificati n 3/4.7.1 re;uirements.

Ea:n of.tnese inacecuate reviews constitutes a separate violation which con ribated to an a::icent; a civil penalty of 55,000 is imposed for 830..

(Cu ula-ive Civil Penal y $10,000)

Te:nnicsl 5:e:ificati:n 6.5, "Procecures," recuires in Se:: ion 6.S.1 tnat are:ecures e establisne:, implemen ed and maintainec covering icentifiec a::ivities.

A.

Emergency Procecure 2202-1.5, " Pressurizer System Failure," Revision 3, requires in Section A.2.B.1 that electromatic relief isolation valve RC-R2 be closed if, among other tnings, the valve discharge line temoerature exceecs the normal 130*F.

Centrary :: the a:cve, the electrematic relief valve dis:narge line te :erature na ceen in tne range of 15C -200*F since Oc ::er of 1975 ar: isolatien valve RC-R2 was not closed as cf 0400 nours on Ma :n 25, 1975.

A:ditionally, on March 25, 1975, ne disenarge line temoerature of 253 F was nctec at 0521 hours0.00603 days <br />0.145 hours <br />8.614418e-4 weeks <br />1.982405e-4 months <br />, out tne isolation valve RC-R2 was not closed until 0519 hours0.00601 days <br />0.144 hours <br />8.581349e-4 weeks <br />1.974795e-4 months <br />, allowing a significan:

loss of RC inventory.

Ea:n day the plant operated in nonccmpliance with this procedure cons-itutes a separate violation, a civil penalty of 55,000 is im:osec for each.

(Cumulative Civil Penalty 5630,000) 8.1 Emergercy Procedure 2202-1.3, " Loss of Reactor Coolant / Reactor Coolant System Pressure," Revision 11, requires in Sections B.2.2.3, B.3.6.2 and A.3.2.5: that high pressure injection is initiated on lo-RCS pressure (1600 psig),and that the operator verify high pressure injection is operating properly as evidenced by ficw in all four legs (250 gpm); tnat flows be maintained at this rate by throttling as RCS pressure drops; and that high pressure injection nc-be terminated until RC5 pressure can be maintained above the reset point (1640 psig) or until low pressure inje: tion flow is es ablished at 3000 gpm.

Cor.trary tc the above:

1.

A about 0405 on March 28, 1979, high pressure injection flow was tnrottlec to minimum concitions even tneugh RC5 pressure was less nan 1500 psi and falling, end witnout low pressure irje: ion flow esteclisnec.

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2.

A various tices tnrougnout the day of Marcn 28, 1979, the hign pressure injection system was modified su:h that tne require:

flow rates were not maintainea during continuing low pressure conditions witnin ne RCS following the period when the reactor coolant pumps -ere s opped anc the hign pressure i'njection system was the only cooe available for the removal of core decay heat.

B.2 Emergency Procedure 2202-1 2, " Loss of Reacter Coolant / Reactor Coolant System Pressure," Revision 11, recuires certain actions t: be taken fcllowing tne automa-ic initiation of hign oressure inie: tion, inciu:in; in Se: tion E.3.1, tnat all E5F ecuipner.:

is verified t: be in its ISF position (casa:ie of performin; its intence: function).

C:ntrary to t e a: eve, curing ine cario: of a: roximately 0500 'ncurs un-il '.200 neers on Maren 25, 1975. curin; cen-inuing icw :ressure c:ncitiens wit-in tne F.05, tne Core.:100: Syste was removed fre-its ESF pesi-ion (rencered inoceracle) by clesing cath tang isola-tior valves.

[Tnis portion of the E5F was inactivated curing a perio: wnen re:u: tion of Reacter Coolant System pressure was not tne immediate gea'..

This removed from service tnis safety feature, during a peric: when it couic nave been callec uren.

In tne course.

of the a::icer.t wnile attac: ting to cearessurize to activate the decay neat rem:vai system NR recogni:e: Inst it was necessary to isolate tne cc e ficoc system anc encourace: this atticn.

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1::iy 10 iscia-icn curi.2.g tnis a tempt.l.

Tr.is vicia-i: ::-.ri:u e: :: a. a::ics t.

(Civil Fenai ;. 55,C::;

C.

Operating Procedure 2104-5.2, " Emergency Diesels and Auxiliaries,"

Revision 9, establisnes the procecures for tne control of tne emergency diesel generators:

1.

Section 4.10, " Diesel Generator - Automatic Start Uoon Engineered Safety Features Actuation," states in the closing step, 4.10.6, that the unit can be shutcown after the Engineered Safeguards Feature actuatien has been cleared.

2.

Section 4.6, " Diesel Generator 1A(15) Snutdown to Emergency Stancby," states in the closing step, 4.6.6, to place the diesel generator on standoy in accordance with Section 4.2; anc 3.

Section 4.2. when completed, establishes conditions for automatically starting the diesels upon actuation of an Engineere: Safeguarcs Feature (ESF) including recuirements' b

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6-to place the " Emergency Standsy/ Maintenance Exercise" switch in :ne Emergency Stancsy position and resetting the fuel ra:ks.

f Contrary to tne above, at about O'50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> on March 28, 1979, both the 14 an: 13 diesel generator fuel racks were manually tripped, thereby preventing an automatic start cf the diesel generat:rs upon E5F a:tuation anc manual start from the control until 0945 hours0.0109 days <br />0.263 hours <br />0.00156 weeks <br />3.595725e-4 months <br />.

inis violation nac'tne ootential to contricute to an accicer..

(Civil Penalty 54,000)

O.

Emergency Pro:e:ure 22C2-2.2 "Less of Feecoater," Revisier 3, recuires in Se:-icn 2.E.2.c that ne c: era :r adjust fasc fic..

c:ntrol stea gene a r levels at 30 inenes.

Contrarp to tne a:ove, frcm ap roximately 0532 hours0.00616 days <br />0.148 hours <br />8.796296e-4 weeks <br />2.02426e-4 months <br /> until 0543 hours0.00628 days <br />0.151 hours <br />8.978175e-4 weeks <br />2.066115e-4 months <br />, the level in A steam generator decreased to 10 inches (the minimum level indication) while tne A steam generator level was being controllec manually.

Tais is an. infra:tien.

(Civil Penalty 53,000)

E.

Inree Mile Islanc Nuclea-Statien A:ministrative Frececure 10;*,

"Tnree Mile Islan: Emergency Pian 1004." Revisien 2, cate:

Fecruary 15, 1375:

. Retuires 'in 5e:-i:n 2.1, tnat tne "Sta-ion sucerintencen,

Senice Uni-Superintencent Unit Suot./Shif t Supervisor / Unit Suet. - Technical Sup ort in the Control Recm will, after reviewing the emergency conditions, classify tne emergency as one of the following:

- "a.

Personnel or Local Emergency, "b.

Site Emergency, and "c.

General Emergency "He will make this classification according to the condition of Table 1 of this Plan, and initiate actions according to the Emergency Plan Implementing Procedures, ano according to his own best judgment;" and 2.

States in Table 1 cf Section 2.1 that a Site Emergency exists i

wnen there is a reactor building high range gamma monitor alert alarm (Cencitien No. e).

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Centrary to the a:ove:

1.

Acequate written procedures were not estaclished and implemented in that Section 2.1 of Proce:ure 1004 for implementing the Emergency Plan lacked sufficient specificity and failed to result in a Site Emergency being declared at approximately 0430 on March 28, 1979, even though primary system pressure had de:reased to the point where safety injection was automatically initiate:

a r.: a rea: or buiicing sump hign level alar = existe:; an:

2.

A site emergency was nc ce:lared at 0525 nours on Mar:n 25, 1975, at wni:n time Condi-ior. "e" of Tnree Mile Islan:

Emergency Plan 1004 ha: c::urred.

Inis is an infra: tion.

(Civil Penal y 54,000)

F.

Tnree Mile Island Nuclear Station Health Physics Prccedure 1570.9, " Emergency Training and Emergency Orills," Revision 4, datec January 15, 1975:

1.

Icentifies in Section 3.1. tne en-site emergency jc:

ca egories an: recuires tnat raining programs for tnese categcries will ce concu:tec en an annual (calencar yea-;

casis; an:

Des: rices in 3e:-ic.. 2.. _ tnrcugn 3.1. 9.

ne - ainin; r: gram for ali cr-site energency jos categorie.

Centrary to the above, curing calencar year 1978, not all individuals having emergency responsibilities were trainec ir that two Emergency Directors, one Accident Assessment indivicual, eight Radiological Monitoring Team Members, and 37 Repair Party Team Members had not received the specified training.

In addition on March 28, 1979, during an emergency, at least four individuals who were assigned as required members of a Radiological Monitoring Team and seven individuals who we e assignec as recuired members of a Repair Party Team per-fermec emergency duties for which they were not trained.

This is an infraction.

(Civil Penalty 54,000)

G.

Station Administrative Procedure 1002, " Rules for the Drotection of Employees Working on Electrical and Mechanical A paratus," Revision 14, requires in Section 4.3, 4.4 and 4.5 tnat on restoration of equipment to service, removed tags will have all recuired information entered thereen and tnen be suitably l

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8-store, and tnat tne shif foreman shall approve equipment operation by sig.ning the original tagging application.

Adci-tionally, Station Corre:tive Maintenan:e Procedure l*07-1, Revision 0, specifies in Section 5.0, " Job Ticket (Work Request)

Flow," the step-by-step process for initiating, processing, obtaining approvals and ultimate filing of the " Job Package" which will include, among otner things, documentation of corrective action taxen (resolution descrip-ion and certi-fication of satisfa: tory post maintenance testing) and Station Preventative Maintenance Procedure E-2, " Dielectric Cne:k cf Insulation, Mctors and Cables," spe:ifies how to make tne measurements anc contains data sneets for recor:ing the values measure:.

Contrary to tne above, wnen instec ed on June 20, 1979, tne tagging acclication coule not ce foun: for maintenance per-1 formec in January,1979, on Emergency Feecwater isolation valves (EP-V12A,125, 32A, 323, 33A, and 33B).

No suit,able documentation to cetermine wnether the maintenance work hac been completec, tags removec, accectance criteria met, or vaives acproved for operation couic be foun:,

Tne TMI-2 maintenance lo; lists inis work recues; as osing in an coen status as of Juna 20, 1975.

Tnis is a deficien:y.

(Civil Fenaity 52.0CT.:

i.

Tecnnical 5:e:ifica-icn 5.5 "Proca:ures," reouires in ie::ic-6.S.2 tna; cnanges to crocecures wnicn implemen: tne Emergen:3 Pian shall be reviewec by the Plant Operations Review Ccamittee and approved by tne Unit Superintencent prior to imolementation.

Contrary to the above, a change to Station Health Pnysics Pro:ecure 1670.7, " Emergency Assembly, Accountability and Evaluation," was made without the required review and approval.

An additional assembly area was designated and the method used 1

to perform accountability was modified by a memorancum cated October 13, 1978, from the Radiation Protection Suoervisor to all departments.

As a result, on March 28, 1979, in response 1

to an emergency, some licensee personnel followed the approved procedure while others followed the guidance in the October 13, 1978 memorandum, creating some confusion and delaying prompt attainment of full accountability.

This is an infraction.

(Civil Penalty 54,000) i 6.

Environmental Tecnnical Specification 5.7 requires that cetailec written crocecures for instrument calicration ce creoare: anc folic-s:.

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.l' 9-Three Mile Island Nu: lear Station Surveillance Proceoure 1302-5.2c, Revision 3, dated Decem:er 19, 1974, specifies tne mstnoc of calieration and recuires that it be performed annually.

Contrary to the above, as of March 29, 1979, eight environmental samplers had not been calibrated since 1974.

This is an infraction.

(Civil Penalty 54,000) itchnical Specification 6.2, "Organi:ation," states in e.

Section 6.2.1 and 6.2.2 that tne unit organi:ation and the organi:ation of the corporate technical support staff shall be as snown on Figure 6.2-1.

Contrary to the above, on March 28, 1979, the organi:ation of the unit and corporate technical support staff was different from that specified in Figure 6.2-1 in that:

A.

A position titled, " Superintendent of Administra-ion and Technical Support" was added to tne organi:ation on September 15, 1975 and filled on March 1, 1979, suen tnat tne "Suoervisor, Raciation Protection and Chemistry,"

reported to this new position ratner than directly to the " Station Superintencent/ Senior Unit Superintencent;"

and E.

There were two " Supervisor of Maintenance" positions, one for eacn unit, rather than onc; and C.

A position titled "Suoerintencent of Maintenance" had teen adced such that the " Supervisors of Maintenance" report to this new position rather than directly to the

" Station Superintencent (Station Manager)/ Senior Unit Superintencent;" anc D.

The position of " Chemical Suoervisor" had been vacant since the issuance of the Technical Specifications.

On March 28, 1979 through March 30, 1979, the above organi:ational ciscrecancies decreased the effectiveness of the licensee's response to the accident.

This is an infraction.

(Civil Penalty S?,000) 8.

Technical Specification 6.4 " Training," recuires that a retraining and replacement training program for the unit staff De maintained tnat meets or exceeds the requirements and reccmmencations of Section 5.5 of ANSI N18.1-1971.

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Ccntrary to the above, as of March 28, 1979, a retraining program meeting or exceeding ANSI N12.1-1971 recommencations hac n been maintained for members of the radiation protection and enemistry staff in that only 2 of the 10 topics recommended were included in the program.

Inis is an infraction.

(Civil Penalty 54,000) 9.

Technical Specification 3/4.4.6, "Reafter Coolant System Leakage," requires in Section 3.4.5.2, that Reactor Coolant Syste.- (RC5) leakage be limited to 1 gallon per minute (GPM) of "Unicentified Leakage," and that unless rates above this limit are reduced to witnin the limit within four hours, the plant must be placed in " Hot Standby" in the next six hours and in " Cold Snutdown" in the next thirty hours.

Contrary to the above, from March 22 until March 28, 1979, RCS i

" Unidentified Leakage" remained above 1 gpm, and the plant was not placed in " Cold Shutdown."

Each cay constitutes a separate infraction; a civil penalty of 53,000 is imposed for each.

(Cumulative Civil Penalty 521,000) 10.

10 CFR 20.401, " Records of surveys, radiaticn monitoring, anc disposal," recuires in Section (a) that each licensee maintain records showing the radiation exposur.e for all individuals for whom personnel monitoring is recuired on a Form NRC-5 or equivalent and in Section (b) requires that eacn licensee maintain records of tne results of surveys requirec by 10 CFR 20.201(b).

Contrary to the above:

A.

The results of approximately 500 ground level radiation surveys conducted during March 2S-30, 1979 in offsite areas borcering the Three Mile Island site were not documented in a manner which permitted a precise evaluation of the type of radiation (Beta / Gamma) which existed in the environs.

Pertinent information sucn as the type of instrumentation used and whether the end wincow on tne probe was open or closed was not recorded.

B.

The records of the radiation exposure for at least 5 individuals exposed during the period March I to 31, 1979 had not been recorded or maintained on a form NRC-5 er ecuivalent as of July 5, 1979.

Furthermore, as of July 5, 1979 the assessment of their doses had not been completed.

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This is an infraction. (Civil Penalty 54,000) 11.

10 CFR 50, Appendix S. Criterion X, " Inspection," requires that a program for inspection of activities affecting quality shall be established anc executed to verify conformance with documented instructions, procedures and drawings for accomplishing the activity.

Three Mile Island Nudlear Station - Unit 2, Final Safety Analysis Report, Chapter 17.2.15,Section X, requires that the inspection program include random observation of operations and functional testing by individuals independent of the activity being performed.

Procedure GP 4014, "QQA Surveillance Program," Revision 0, requires independent observation of activities affecting quality to verify conformance with established requirements utilizing both inspection and auditing techniques...for compliance with written procedures and the Technical Speci-fications.

Contrary to the acove, as of March 28, 1979, the normal operations surveillance testing activities had not been made subject to rancom and/or routine inspections by indepencent methods.

This is an infraction.

(Civil Penalty S3,000)

This Notice of Violation is sent to Metropolitan Edison Company pursuant tc t e provisions of Section 2.201 of tne NRC's " Rules of Practice," Part 2, Ti-!s 10, Coce of Federal Regulations.

Metropolitan Edison Company is hereby recc'ree to submit to this office witnin twenty (20) cays of the receipt of this Notice, a written statement or explanation in reply, including for each iter of noncompliance: (1) acmission or denial of the alleged items of non-compliance; (2) tne reasons for the items of noncompliance if acmitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further items of noncom-lian:e; and, (5) tne date when full compliance will be achieved.

7he total civil penalties for all items cited is 5725,000.

However, pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (42 USC 22S2), the total of civil genalties for any nirty day period cannot exceed $25,000.

l Consecuently 5570,000 has been subtracted to reduce the total penalties to l

525.000 for eacn 30 day period resulting in the total civil penalty herein crc:: sed of 5155,000.

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APPENDIX B NOTICE OF DR0705EE IMP 351 TION OF CIVIL PENALTIE5 "str:p:litan Ecison Company Docket No. 50-320 License No. DPR-73 T ds office has considered the er.forcement options available to the NRC including i

a:?.i-istrative a:tions in the form of written Notices of Violation, Civil l

One:a y Penalties, and Orders pertaining to the modification, suspension or e.c:ation of a license.

Basec on these considerations we propose to impose civil penalties cursuant to Section 234 of the Atomic Energy Act of 1954, as amen:ed (42 USC 2252), and t: 10 CFR 2.205 in tne cumulative amount of One hun: e: an: Fifty-Five Thousand Dollars (5155,000) for the specific items of none:m;1iance set forth in A;oencix A to the couer letter. In proposing to imcose civil penalties pursuant to this section of the Act and in fixing the crop: sed amount of the penalties, the factors identified in the Statements of Constdaration published in tne Federal Register with the rulemaking action whics accoted 10 CFR 2.205 (35 FR 15894) August 26, 1971, and the " Criteria for Cetermining Enforcement Action," which was sent to NRC licensees on Decemoer 31, 1974, have been taken into account.

Mett:: litan Edison Company may, within twenty (20) days of receipt of this hoti:2 pay the civil penalties in the cumulative amount or may protest the im:csition of tne civil penalties in whole or in part by a written answer.

Should Metrocoli an Edison Company fail to answer within the time specified,

-his offica will issue an Orcar i.rposing tne civil penalties in the amount

rop: sed atove.

Should Metr colitan Edison Com:any elect to file an answer

rotes-ir.g the civil penalties, such answer may (a) deny tne items of noncom-siia :e listec in the Notice of Violation in whole or in part, (b) demonstrate ex e.uating circums ances, (c) snow error in the Notice of Violation, or (d) sh:w otner reasons why the penal-ies should not be imposec.

In aceition to

rciss-ing the civil penalties in wnoie or in part, such answer may recuest remissio cr mitigation of the penalties.

Any written answer in a::creance with IC CFR 2.205 shculd be set fortn separately from the statement or explana-tion in re:iy pursuant to 10 CFR 2.201, but may incorporate by specific reference (e.g., g'ving page and paragraon numbers) to avoid repetition.

Metr:politan Edi:en Company's attention is directed to the other provisions of 10 CFR 2.2C5 regarcing, in particular, failure to answer and ensuing orders; ans-sr, consideration by this office, and ensuing ceners; requests for hearings, nearings and ensuing orders; ccm romise; and collection.

upon failure to pay any civil penalties due which have been subsequently cete mined in a::orcance witn tne applicable provisions of 10 CFR 2.205, the i

matter may be referred to the Attorney General, and the penalties, unless

m: Otisec, remitte=, or mitigated, may be collected by civil action pursuant t: Section 234: of the Atomic Energy Act of 1954, as amenced (42 USC 22S2).

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