ML20030D069
| ML20030D069 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/05/1981 |
| From: | Hovey G METROPOLITAN EDISON CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20030D066 | List: |
| References | |
| LL2-81-0120, LL2-81-120, NUDOCS 8108310354 | |
| Download: ML20030D069 (4) | |
Text
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Metropolitan Edison Company Post Office Box 480 g
Middletown, Pennsylvania 17057 Writers Dirat Dial Number May 5, 1981 LL2 0120 Office of Inspection and Enforcement Attn:
Mr. Boyce H. Grier, Director Region I U. S. Nuclecr Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Sir:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Inspection Report 50-320/80-17 This is in response to the subject Inspection Report issued on March 20, 1981.
By means of our letter of April 14, 1981 (LL2-81-0099) and subsequent discussions by Mr. S. D. Chaplin of TMI-2 Licensing with Mr.
P.. J. Conte, Senior Resident Inspector TMIPO, USNRC, we informed you of the delay in the submittal of our response. The following herein is our response to Inspection Report 80-17 in accordance with the above mentioned communications.
Item A - Apparent Deficiency Contrary to Technical Specification 6.4.1, as of December 6, lo80 a retraining and replacement training program for the unit radiological controls department was maintained under the direction of the Manager-Radiological Controls and not under the direction of the Supervisor-Station Training as required in the Specifications.
Response
In order to improve the qualifications of the TMI-2 Radiological Controls Technicians (Rad. Con. Tech.) a Rad. Con. Tech.
Training / Qualification program was established under the direction of the newly formed Unit 2 Radiological Control Training Department in November 1979.
This was in response to both company and NRC concerns and also recommendations by an independent consultant in November 1979. The concept of having the training program under the direction of the Radio-logical Controls Department was endorsed by the Report of the Special Panel in December 1979 (NUREG 0640).
Oo O
PDR Atan Ed; son Cornpany is a Member cf the General Puche Utihties System
Mr. Boyce H. Grier LL2-81-0120 In February 1980, the Proposed Technical Specifications were issued.
Section 6.4.1 required a training and replacement training program under the direction of the Supervisor-Station Training to meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix "A" to 10CFR55.
Since it was not clear that Rad.
Con. Tech. training was within the scope of the referenced ANSI standard,the discrepancy with the Tech. Spec. was not recognized. To correct this situation a Tech. Spec. Change Request will be submitted by May 29, 1981 to remove Rad. Con.
Tech. training from the cognizance of the Supervisor-Station Training.
This change will allow the continuance of the increased management attention and commitment afforded by Rad. Con. Department direction of Rad. Con. Tech. Training.
Item B (1) - Apparent Deficiency On October 3, 1980, Operating Procedure 2104-4,13, Revision 7, dated September 10, 1980, titled Transfer of Radioactive Resin Liners from EPICOR-I to On Site Staging Facili;y and from Staging Facility to Shipping Cask was not implemented as required in that an outdated procedure 2104-4.13, Revision 6, dated June 9, 1980, was used.
Response
The Licensee contests the validity of this apparent deficiency, At the time of the operation on October 3, 1980, Revision 6 of the subject procedure was still the currently effective revision and as such was the only correct revision to utilize during the operation.
The citation of noncompliance with Administrative Procedure (AP) 1001 is apparently based on the premise that the procedure date, the date of the Manager-Site Operations approval, is equivalent to the implementation date. Although ideally it would be desireable to approach just_that, in reality there are typically many steps, and therefore, some length of time between approval by the Manager-Site Operations and the actual availability of the procedure for implementation.
At TMI-2, a procedure is not availabic for implementation until the appropriate processing is complete.
The end point of this processing is defined by AP1001 in section 3.4 " Procedural Control" which states "All procedures distributed.
. to Met-Ed personnel at TMI are considered controlled and are stamped with a red ' con-trolled copy' stamp at the time of distribution.
Controlled procedures only are to be used for maintenance and operations of the plant.
Copies of controlled procedures may be made for l
immediate use in plant operations." On tober 3, 1980, revision l
6 of the subject procedure was the controlled copy of file in the Unit 2 control room and was the source of the working copy used during the operation.
Revis ion 7, which was still in the approval and distribution process at the time, had not yet replaced revision 6 l
as the controlled copy. Therefore, the implementation of revision 6 during the operation was the correct version to use and was in full compliance with AP 1001.
y Mr. Boyce H. Grier LL2-81-0120 Item B (2) - Apparent Deficiency On Octo'er 3, 1980, Administrative Procedure 1001 was not o
implemented as required in that step-by-step sign off was not completed on the Shield Plug Hold-Down Stud Torquing Procedure of Operating Procedure 2104-4.13, Revision 6, dated June 9, 1980, when performing the transfer of an EPICOR-1 liner to the shipping cask.
Response
Operating Procedure 2104-4.13 Rev. 6 is designed to cover multiple operation involving 6 x 6 liner transfers.
In each operation, the applicable part(s) of the procedure and their associated attachments are completed and signed off.
By virtue of the construction of this procedure, unused portions are not signed off or indicated as not applicable. This is recognized in scetion 4.3.5 and 4.4.5 of the procedure in its directions that " Opening, loading and closing of cask shall be performec in accordance with cask supplier's handling procedure modifiet to suit specific conditions.
Therefore, portions of the procedure unnecessary to the evolution need not be per-formed. as allowed.for by Administration Procedure 1001 part 3.8.5 (b). The evolution on October 3, 1980 used specific sections of the procedure, as indicated by those sections signed off, but did not use the Shield Plug Stud Torquing Section (Attachment III, part IILB shield Plug Hold-Down Studs).
There are only two reasons for evoking Attachment III Part III.B, first, removal of the shield plug when necessary during the operation and, secondly, to inspect the shield plug gasket as required in Attachment II.C.
Both cases require reinstall-ation of the shield plug and proper retorquing of the studs per Attachment III part III.B before completion of the overall evolution.
During an evolution such as that on October 3, 1980, the shield plug is not removed.
In Addition, the inspection requirement of the shield plug gasket was satisfied during the evolution by our verification that the shipning cask vendor provided documentatiaa that the shield plug ga sket has been replaced within the last twelve (12) months, la accordance with the requirements of the Certification of Compliance, and that the lid was sealed with the vendor's seal.
Therefore, in the absence of any reason for removal, reinstallment and torquing of the shield plug, Attachment III, part III.B of the procedure l
was not used.
As stated above, unused portions of the procedure are not signed off or required to be marked not applicable. This is not in I
Mr. Boyce H. Grier LL2-81-0120 violation of any of the requirements stated in Administrative Procedure 1001. Therefore, it is Licensees contention that a noncompliance did not exist and that the apparent deficiency is indeed an apparent misconception on the NRC inspectors part.
Sincerely,
. K. Hovey Vice-President and Director, TMI-2 GKH:SDC:vjf cc:
L. H. Barrett, Deputy Program Director Dr. B. J. Snyder, Program Director - TMI Program Office I
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