ML20054C408
| ML20054C408 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/01/1982 |
| From: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20054C406 | List: |
| References | |
| 50-320-82-01, 50-320-82-1, NUDOCS 8204210008 | |
| Download: ML20054C408 (2) | |
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APPENDIX A NOTICE OF VIOLATION GPU Nuclear Corporation Docket No. 50-320 Three Mile Island Unit 2 License No. OPR-73 As a result of the inspection conducted on January 17 - February 15, 1982, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980),
the following violations were identified.
A.
10 CFR 50, Appendix B, Criterion VI and the approved TMI-2 Recovery Quality Assurance Plan *, Revision 0, July 14, 1980, Section 3.2.1 require, in part, that measures be established to control the issuance of documents such as procedures and that these measures assure these documents are reviewed for adequacy.
Contrary to the above, as of February 15, 1982, measures were not established to assure that operating procedures were controlled and reviewed for adequacy prior to the work initiation of a modification, when that modification prevented the proper implementation of an operating procedure.
Certain Long Term "B" Cooling (LTB) System piping was disassembled without revision and review for adequacy of the associated operating procedure (2106-2.9, Revision 2, September 15,1981).
This piping was used in the fill and vent evolution specified in the operating procedure for startup of the LTB System.
This is a Severity Level IV Violation (Supplement 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 requirements set forth in Attachment 1..."
(Proposed Technical Specification, Appendix A to License No. DPR-73).
The proposed Technical Specification 6.8.1.a requires in part that procedures for performing maintenance be implemented. Administrative Procedure 1021B, Revision 8, January 13, 1981, Plant Modifications, paragraph 4.1.a requires, in part, that when a work request represents a change / modification to a system, the change / modification form and associated safety evaluation is to be completed.
- By NRC letter dated March 20, 1980 from B. Snyder to G. Hovey 0FFICIAL RECORD COPY 8204210008 820401 DR ADOCK 05000320 PDR
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o Appendix A 2
Contrary to the above, between November 23, 1981 and December 30, 1981, a change / modification form and associated safety evaluation was not completed for a Job Ticket (Work Request) No. C8576, dated November 23, 1981, and approved for work (by the Maintenance Depar ment) on December 30, 1981.
This Job Ticket caused the construction of a fourth wall and the addition of heaters to an enclosure adjacent to the Borated Water Storage Tank (BWST).
This action enclosed certain BWST piping along with temperature sensors for primary heating tracing that heat traced piping inside and outside of the enclosure.
This is a Severity Level IV Violation (Supplement I).
C.
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 Specification, Appendix A to License No. DPR-73). The proposed Technical Specification 6.8.1.c states in part: " Written procedures shall be... established... covering the test activities of... radioactive waste management equipment".
Contrary to the above, on January 8, 1982, a High Efficiency Particulate Absolute (HEPA) Filter on a vacuum cleaner (in the dry vac mode) was used without having established procedures for testing the integrity of the in place HEPA filter. The vacuum cleaner was used as radioactive waste management equipment during decontamination of radioactively contaminated equipment, at the 281' elevation of the Unit 2 Auxiliary Building.
This is a Severity Level V Violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, GPU Nuclear Corporation is hereby required to submit to this office within 30 days of the date of this Notice, a written statement or explanation in reply, including (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation. Where good cause is shown, consideration will be given to extending your response
- time, poR01 I OriSinal Signed By:
Dated Richard W. Starostecki, Director Division of Project and Resident Programs 0FFICIAL RECORD COPY
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