ML20032B576
| ML20032B576 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/02/1981 |
| From: | Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20032B553 | List: |
| References | |
| 50-320-81-15, NUDOCS 8111050679 | |
| Download: ML20032B576 (4) | |
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APPENDIX A NOTICE OF VIOLATION Metropolitan Edison Company Docket No. 50-320 Three Mile Island Unit 2 License No. DPR-73 As a result of the inspection conducted on August 12, 1981 through i
September 10, 1981, and in accordance with the Interin Enforcement Policy, 45 FR 66754 (October 7,'1980), the following violations were identified.
A.
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, i
the lict asee shall maintain the facility in accordance with the reqcimments set forth in Attachment 1..." (proposed Technical Specifications, Appendix A to License No. DPR-73). The proposed i
Technical Specification 3.9.12 states in part: "With no... auxiliary building air cleanup system OPERABLE, suspend all operations involving movement of liquid and gaseous radioactive wastes until at least one fuel handling building /nxiliary building air cleanup system is restored tv OPERABLE status."
The proposed Technical Specification 4.0.1 states in part:
...The Surveillance Requirements shall be performed to demonstrate compliance with the OPERABILITY requirements of the Limiting Conditions for Operations and in accordance with the RECOVERY OPERATIONS PLAN...."
The Recovery Operations Plan, section 4.9.12 states in part:
"...The... auxiliary building air cleanup system shall be demonstrated OPERABLE:...by:... Verifying an exhaust flow rate of at least 65,000 cfla for the auxiliary building air cleanup system with two auxiliary building supply fans and two auxiliary building exhaust fans in operation...."
Contrary to the above requirements, during the time period August 1,1981 to September 2,1981 several movements of liquid wastes were made in the auxiliary building although the air cleanup system flow rate was less than 60,000 cfin with two supply and two exhaust fans in operation.
This is a Severity Level IV Violation (Suppleannt I).
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 Append 1F A to License No. DPR-73). The proposed Technical Specification 4.0.1 states in part:
...The Surveillance Requirements shel be performed to demonstrate compliance with the OPERABILITY requirements of the Limiting Conditions for Operations and in accordance with the RECOVERY OPER/.TIONS PLAN...."
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The Recovery Operations Plan, section 4.7.7.1 states in part: "The control room emergency air cleanup system shall be demonstrated OPERABLE:...by... Verifying within 31 days after remval that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978 " Regulatory Position C.6.a stipulates a methyl iodide penetration of less than 1% (99% removal).
Contrary to the above requirement, the carbon sample from the control room emergency air cleanup system tested on May 15, 1980 passed the licensee's acceptance test criteria although it had a methyl iodide penetration of greater than 4%. Test results indicated 95.29% remaval efficiency (4.71% penetration).
This is a Severity Level IV Violation (Supplement I).
C.
Environmental Technical Specification 2.1.2.I requires that the reactor building purge exhaust gas monitors HP-R-225 and HP-R-226 have an instrument channel test at least monthly.
Contrary to the above requirements, the monthly instrument channel test was not performed during the months of February, March, April, May and July 1981.
This is a Severity Level IV Violation (Supplement I).
D.
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 to License No. DPR-73). The proposed Technical Specification 4.0.1 states in part:
...The Surveillance Requirements shall be perfomed to demonstrate compliance with the OPERABILITY requirements of the Limiting Co,ditions for Operations and in accordance with the RECOVERY OPERATIONS PLAN...."
The Recovery Operations Plan, section 4.9.12 states in part: "The fuel handling building air cleanup system and the auxiliary building air cleanup system shall,be demonstrated OPERABLE...by... Verifying a flow rate of 23,000 cfm + 104 for each fuel handling building exhaust filte train when tested in accordance with ANSI M510-1975....
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Verifying a flow rate of 36,000 cfts + 10% for each auxiliary building exhaust filter train when tested in accordance with ANSI M510-1975."
ANSI M510-1975 requires that air flow capacity tests be performed by a pitot-tube traverse or."one of the other methods described in Section 9 of the ACGIH [Anerican Conference of Governmental Industrial Hygienists 1 Industrial Vent 11atio_n".
Contrary to the above requirements, tests of flow rate for the auxiliary building and fuel handling building ventilation systems conducted on May 14 and 15,1980 were not performed in accordance with ANSI N510-1975 The method used was not a pitot-tube traverse or "one of the other methods described in Section 9 of the ACGIH Indust _ rial Ven_tilation".
This is a Severity lmvel VI Violation (Supplement I).
E.
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 requirmeents set forth in Attachment 1..." (proposed Technical Specifications. Appendix A to License No. DPR-73).
The pm posed Technical Specification 4.0.1 states in part:
...The Surve111tnce Requirements shall be perfonned to demonstrate compliance with the OPERABILITY requirements of the Limiting conditions for Operations and in accordance with the RECOVERY OPERATIONS PLAN...."
The Recovery Operations Plan, section 4.9.12 states in part: "The fuel j
handling building air cleanup system and the auxiliary bu11' ding air i
cleanup system shall be demonstrated OPERABLE:.:.following painting, fire or chemical release in any ventilation zone communicatira with j
the system by... Verifying a flow rate of 36,000 cfm + 10% for each j
auxiliary building exhaust filter train when tested In accordance -
with ANSI N510-1975".
Contrary to the above requirements, during the period April through July 1981 greater than one thousand square feet of the auxiliary building was painted and the required tests were not performed.
This is a Severity Level VI Violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Metropolitan Edison Company is hereby required to submit to this office within 20 days of the date i
of this Notice, a written statement or explanation in reply, including (1) the corrective steps which have been taken and the results, achieved; i
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(2) corrective steps which will be taken to avoid further violations; and (3) the data when full ccupliance will be achieved. Under the j
authority of Section 182 of the Atomic Energy Act of 1954, as amended, this respor.se shall be submitted under oath or affirmation..tihere good e
cause is shown, consideration will be given to extending your response
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time.
The responses directed by this Notice are not subject t6 the clearance
'l procedures of the Office of Management and Budget as required by the s
Paperwork Reduction Act of 1980, PL 96-511.
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OrigM 21eued Pyr.
Dated 3'
R. R. Keinig, Chief Projects Branch #2, Division of J.
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Resident and Project Inspection
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