ML20033B487

Supplemental Response to NRC Re Violations Noted in IE Insp Rept 50-320/81-12.Corrective Actions:All Copies of Draft Procedure & Guidelines Were Removed

ML20033B487
Person / Time
Site:	Crane
Issue date:	10/30/1981
From:	J. J. Barton METROPOLITAN EDISON CO.
To:	Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20033B485	List: ML20033B487
References
LL2-0252, LL2-252, NUDOCS 8112010458
Download: ML20033B487 (3)

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Metropolitan Edison Company Post Office Box 480 II Middletown, Pennsylvania 17057 Writer's Direct Dial Number October 30, 1981 LL2-81-0252 Office of Inspection.nd Enforcement Attn:

Mr. Ronald C. Haynes, Director Region I U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvrnia 19406

Dear Sir:

Threc Mile Island Nuclear Station, Uni 2 (TMI-2)

Operating License No. DPR-73 Docket No. 50-320 Inspection Report 50-320/81-12 This letter is submitted in response to the subject Inspection Report Item C.1, and is being submitted in accordance with our initial response of October 11, 1981 (LL2-81-0238), and a discussion between Mr. S. Chaplin, TMI-2 Licensing with Mr. R. J. Conte. Senior Resident Inspector, TMIPO, USNRC on October 30, 1981.

Item C - Apparent Violation (Severity Level V)

Contrary to the reauirements of AP 1001 and the Quality Assurance Plan (QAP), between June 30, 1981 and July 2, 1981 uncontrolled instructions and procedures were posted or used around the SDS pool area as noted below.

Item C.1 Various copies of a handwritten, unreviewed and unapproved PING (Particulate Iodine Noble Gas) Monitor Operation Procedure at the SDS Off Gas Syctem PING mer.itor were posted and were at the operator's desk.

Response

Apparently the " handwritten procedure" was an initial distillation of notes and guidelines assembled during the installation and initial testing of the tritium bubbler on the PING unit. This compilation was not intended as a procedure in itself.

" Drafts" such as this can be beneficial in ensuring that pertinent operational information discerned during initial component line-up is recorded for incorporation into the necessary levels of documentation, such as procedures, training manuals, etc.

However, steps must be taken to ensure that drafts are not used in lieu of procedures.

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h ber of the General Pub!ic Utlittes Systern Met G

.d Mr-Ronald C. Haynes LL2-81-0252 Accordingly, when it became known that the guide was posted on the Eberline PING 1A,and copies were seen on the operator's desk all of the copies were removed from the area.

As of this date there are no known copies of this guide leic any-where in the area of SDS.

Additionally, it will be emphasized to the personnel of the departments involved with the tritium bubbler installation that such guidelines or drafts should not be posted in inappropriate areas and that they must be incorporated in the appropriate information management process i.e. procedure or training development, etc.

This action will be completed by November 30, 1981.

We believe that this action, as supported by the corrective actions associated with other related citations in the remainder of this Inspe.: tion Report, is sufficient to address the deficiency.

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Director, TMI-2 JJB:SDC:djb cc:

L. H. Barrett, Deputy Program Director Dr. B. J. Snyder, Program Director, TMI Program Office i

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METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER AND LIGHi COM@A$Y

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I1 PENNSYLVANIA ELECTRIC COMPANY THREE MILE ISLAND NUCLEAR STATION, UNIT II 4

Operating License No. DPR-73 Docket No. 50-320 This letter is submitted in support of the Nuclear Regulatory Commission request concerning the September 1, 1981 letter transmitting Inspection Report 50-320/

81-12.

The response to the subject Inspection is attached. Further, all state-ment contained in these responses have been reviewed and all such statements-made and matters set forth therein are true and correct to the best of my know-ledge, information and belief.

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et Director, TMI-f Sworn and subscribed to me this 2 4 da of 6, 1981.

By

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