ML20040G853
| ML20040G853 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/08/1982 |
| From: | J. J. Barton GENERAL PUBLIC UTILITIES CORP. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20040G844 | List: |
| References | |
| 4400-82-L-0008, 4400-82-L-8, NUDOCS 8202160538 | |
| Download: ML20040G853 (6) | |
Text
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OPU Nuclear g
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P.O. Box 480 Middletown, Pennsylvania 17057 717-944-7621 rgr sgt Dial Number:
4400-82-L-0008 Office of Inspection and Enforcement Attn:
Mr. Ronald C. Haynes, Director Region I U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Sir:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Inspection Report 81-15 This is in response to the subject Inspection Report issued October 06, 1981 and is being submitted in accordance with the provisions of the report and our letter of October 26, 1981 (LL2-81-0249) and a discussion between Mr. S. D. Chaplin of TMI-2 Licensing with Mr. R. J. Conte, Senior Resident Inspector (TMI-2) USNRC on November 6, 1981.
Item A - Apparent Violation (Severity Level IV)
Contrary to the requirements of the Recovery Operations Plan, Section 4.9.12, during the timc 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 cfm with two supply and two exhaust fans in operation.
Response
cm,b
~6 The response to this item is not yet complete.
It will be submitted by "O
February 5, 1982.
5 oo 9]
Item 8 - Apparent Violation (Severity Level IV)
Om Contrary to requirements of the Recovery Operations Plan, Section 80 4.7.7.1, the carbon sample from the control room emergency air cleanup g
system testeri on May 15, 1980 passed the licensee's acceptance test crua criteria although it had a methyl iodide penetration of greater than "O
4%.
Test results indicated 95.29% removal efficiency (4.71%
penetration). This is in excess of the referenced requirements of Reg.
Guide 1.52, Section C.6.a which stipulates a methyl iodide penetration of less than 1%.
GPU Nuclear is a part of the General Public Utilities System
1 Mr. Ronald C. Haynes 4400-82-L-0008
Response
The lest procedure was written incorrectly when the " assigned" efficiency of 95% from Reg. Guide 1.52, Table 2, was used in the procedure instead of the " laboratory test" efficiency of 99%. However, in investigating this item it was discerned that utilizing testing criteria in Regulatory Position C.6.a of Reg. Guide 1.52 Rev. 2 March 1978 was not appropriate.
The Control Room Emergency Air Cleanup System does not have in line air heaters to control relative humidity to the charcoal adsorbers and thus does not fall into any of the testing criteria categories specified in Reg. Guide 1.52.
The 1% penetration is a criteria for testing an outside primary containment air filtration system utilizing 2" thick activated carbon bed depths and with relative humidity controlled to 70%.
We have identified an appropriate testing criteria for the carbon in the control room charcoal adsorbers which is equivalent to that in Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978. The testing criteria comes from an approved standard (ANSI /ASME N509-1980) and specifies testing at 95% relative humidity which more accurately reflects actual conditions. The 5% penetration limit varies from that listed in the Reg. Guide because it is based on the decontamination factor of 10 (90% removal efficiency) derived from the original testing discussed in Section 9.4.1 of the TMI-2 FSAR and accepted by the NRC in Section 11.3 of the TMI-2 Safety Evaluation Report, Supplement 1 and thus is consistent with the system's original design bases. We are currently preparing a change request to incorporate the above into the Recovery Operations Plan. The request will be submitted within 45 days of the date of this letter.
Item C - Apparent Violation (Severity Level IV)
Contrary to the requirements of Environmental Tech. Spec. 2.1.2.1, the monthly channel test was not performed for the Reactor Building Purge Exhaust Gas Monitors HP-R-225 and HP-R-226 for the months of February, March, April, May and July 1981.
Response
Upon realizing Surveillance Procedure SP2322-M1 was not scheduled on our computer based surveillance scheduling system, the surveillance was manually scheduled and successfully performed on August 26, 1981. With the successful computer scheduling and completion of the subsequent months test on September 29, 1981, full compliance is considered achieved as of September 29, 1981.
1 Mr. Ronald C. Haynes 4400-82 L-0008 4
Item D - Apparent Violation (Severity Level VI)
Contrary to the requirements of the Recovery Operations Plan, Section 4.9.12, 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 Industrial Ventilation".
Response
The surveillance procedure performing the flow test was written incorrectly in that it required an inappropriate flow measurement nethod. Apparently the flow measurement technique was based on the requirements of the ANSI standard and not the more restrictive requirements of Section 4.9.12 of the Recovery Operations Plan (ROP).
The standard states in Section 8.1 " Purpose" that the test (by one of the designated methods) "is made only during acceptance testing following original installation, modification, or major repair of the air cleaning system". This would not include the 18 month surveillance as performed by the surveillance procedure. However, it is recognized that the requirements of Section 4.9.12 of the Recovery Operations Plan take precedence over the standard in this regard. Therefore, during the last perfomance of the flow test surveillance in September 1981, one of the flowrate measurement methods described in the ANSI standard was utilized. Additionally, Surveillance Procedure 4303-R28, Fuel Handling Building / Auxiliary Building Air Cleanup Performance Analysis, has been modified to include the use of one of the specified flow measurement techniques in ANSI-N510-1975. As of the date of this response, full compliance is considered achieved.
Item E - Apparent Violation (Severity Level VI)
Contrary to the requirements of Recovery Operation Plan, Section 4.9.12, during the period April through July 1981, greater than one thousand -
square feet of the auxiliary building was painted and the ventilation system operability tests were not perfomed.
I
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I L
Mr. Ronald C. Haynes 4-4400-82-L-0008
Response
The response to this item is not yet complete.
It will be submitted by February 5, 1982.
S ely,,,
/
MJ I K arton Act Director, TMI-2 JJB:SDC:kk Attachment cc: L. H. Barrett, Deputy Program Director Dr. B. J. Snyder, Program Director - TMI Program Office
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METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER AND LIGHT COMPANY AND PENNSYLVANIA ELECTRIC COMPANY THREE MILE ISLAND NUCLEAR STATION, UNIT II Operating License No. DPR-73 Docket No. 50-320 This letter is submitted in support of the Nuclear Regulatory Conunission request concerning the October 6, 1981 letter transmitting Inspection Report 50-320/81-15.
The response to the subject Inspection is attached. Further, all statements containad 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 knowledge, information and belief.
By ht
' Director TMI-2 Sworm and subscribed to me this m
day of (% -um w,1982.
i By Dh h4 h Notar3fPublic Q
CAW! A jf AN E[NRY. NOIARY PUBUC MIDDLETOWN BORD. DAUFHIN COUNTY MY COMMISSION EXPlRES JUNE 17.1985 Meetcr. Pennsylvanta Associatk>n cf Netanes
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