ML20032C529
| ML20032C529 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/03/1981 |
| From: | Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | J. J. Barton METROPOLITAN EDISON CO. |
| Shared Package | |
| ML20032C530 | List: |
| References | |
| NUDOCS 8111100540 | |
| Download: ML20032C529 (2) | |
See also: IR 05000320/1981012
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Docket No. 50-320
NOV 3
1981
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Metropolitan Edison Company
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ATTH: Mr. J. J. Barton
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Acting Director of TMI-2
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P.O. Box 480
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Middletown, Pennsylvania 17057
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Gentlemen :
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Subject: Inspection 50-320/81-12
This refers to your letter dated October 11, 1981, in response to our
letter dated September 1,1981.
With respect to your response to the apparent noncompliance B.1 to
Appendix A to our letter, a meeting was held on October 23,1981, at the
site between Mr. R. Conte of our staff with you and other members of
your staff. This is to document our final position and our understanding
of your actions on this matter.
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We agree with your position that a prerequisite to a procedure is the (
means to " identify those independent actions or procedures which shall
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be completed and plant conditions which shall exist prior to the use of
the subject procedure". This is consistent with your NRC approved
Recovery Quality Assurance Plan in which you are committed to American
National Standards Institute (ANSI) N18.7-1976 (paragraph 5.3.2(4)).
However, your response overlooks the generic issue that your organization
established an operability requirement for a radiation monitor as a
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prerequisite to the main body of the procedure without a contingency
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(established procedure / procedural steps) for operator action if the
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radiation monitor became inoperable. Your response recognizes the
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specific inadequacy with respect to the area radiation monitor CN-RIT-IX-03
by a commitment to revise SDS operating procedures for "more specific
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direction involving this detector...when this detector is taken out of
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service".
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At the meeting of October 23, 1981 you_ indicated that other operating
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and special operating procedures may have similar inadequacies and that
a review to establish the scope of this problem would be initiated for
subsequent scheduling of corrective action:..
A date for completion of
this initial review could not be finalized at that meeting.
Therefore ,
we expect that, within 1 month of the date of this letter, you are aware
of the scope of this problem and have scheduled necessary corrective
actions.
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OFFICIAL RECORD COPY
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Metropolitan Edison Company
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Accordingly, the item (B.1) remains an item of noncompliance.
Further
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during the interim review period as noted above, we will continue to
enforce nuclear safety related and important to safety component / system
operability requirements in procedural prerequisites that do not have
adequate contingencies such as limit / precaution actions or other procedural
actions when that equipment becomes inoperable.
Thank you for infoming us of the corrective and preventive actions
documented in your letter. These actions will be examined during a
future inspection of your licensed program.
No response to this letter is required. However, if there are any
misunderstandings contained herein, please inform us as soon as possible.
Your cooperation with us is appreciate...
Sincerely,
R. R. Keinig, Chief
Projects Branch #2, Division of
Resident and Project Inspection
cc:
J. J. Barton, Director, Site Operations
J. E. Larson, Supervisor,1NI-2 Licensing
E. G. Wallace, PWR Licensing Manager
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J. B. Liberman, Esquire
G. F. Trowbridge, Esquire
Public Document Room (PDR) (LPDR)
Local Public Document Room
Nuclear Safety Information Center (NSIC)
HRC Resident Inspector
Commonwealth of Pennsylvania
Ms. Mary V. Southard, Co-Chairman, Citizens for a Safe Environment
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Region I Docket Room (w/ concurrence)
L. Barrett, Deputy Program Director, TMI Program Office
Chief, Operational Support Section
Ms. Mary V. Southard, Co-Chairman, Citizens for a Safe Environment
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