ML20055A720
| ML20055A720 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/22/1982 |
| From: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | J. J. Barton GENERAL PUBLIC UTILITIES CORP. |
| Shared Package | |
| ML20055A721 | List: |
| References | |
| NUDOCS 8207190371 | |
| Download: ML20055A720 (4) | |
See also: IR 05000320/1982004
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2 ? 1982
Docket No. 50-320
GPU Nuclear Corporation
ATTN: Mr. J. J. Barton
Acting Director of TMI-2
P.0 Box 480
Middletown, Pennsylvania 17057
Gentlemen:
Subject:
Inspection 50-320/82-04
This refers to the routine safety inspection conducted by Mr. R. Conte of this
office on March 21 - April 24,1982 of activities authorized by NRC License DPR-
73 and to the discussions of our findings held by Mr. Conte with yourself and
other members of your staff at the conclusion of the inspection.
Areas examined during this inspection are described in the NRC Region I Inspection
Report which is enclosed with this letter. Within these areas, the inspection
consisted of selective examinations of procedures and representative records,
interviews with personnel, and observations by the inspector.
Based on the results of this inspection, it appears that certain of your activities
were not conducted in full compliance with NRC requirements, as set forth in the
Notice of Violation, enclosed herewith as Appendix A.
These violations have
been categorized into the levels described in the Federal-Register Notice (47 FR 9987) dated March 9, 1982.
You are required to respond to this letter and in
preparing your response, you should follow the instructions in Appendix A.
The responses directed by this letter and the accompanying Notice are not
subject to the clearance procedures of the Office of Management and Budget as
required by the Paperwork Reduction Act of 1980, PL 96-511.
Additionally,an apparent violation of NRC requirements is described in the
inspection report (paragraph ll.d) enclosed with this letter. We are considering
this item for appropriate enforcement action and will be addressing this matter
under separate correspondence at a later time. However, as a part of our review
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of this matter., we want to discuss with you the circumstances surrounding this
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and other related apparent violations. You will be contacted subsequently
regarding a mutually acceptable date and time for a management conference.
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We are particularly concerned about the adequacy of your corrective action
system that allowed activities adverse to quality associated with the operation
of the Reactor Building (RB) Purge, Auxiliary Building (AB) and Fuel Handling
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Building (FHB) Ventilation Systems to go apparently uncorrected.
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In June of 1980, maintenance records associated with filter replacement identified
filter bypassing in the RB purge filter trains due to the filter cabinet under-
drain system. The corrective action to stop the bypassing was to use " tuck
tape" contrary to plant drawings and specifications.
In September of 1980,
inspection and testing of High Efficiency Particulate Absolute (HEPA) filters
following filter replacement for the AB Ventilation System were conducted in
accordance with maintenance procedures and using a checklist (apparently an
excerpt from ANSI N510-1975) to assure that there was no bypassing via the drain
system.
Documentation of as-found conditions was lacking, but it appears from
maintenance recori that a specific check for conformance to drawings and speciff-
cations was not performed. A similar replacement of FHB Ventilation filters
occurred in September 1981 based on a request for work in November 1980. Still,
the nonconformance was not identified.
As a result of an unusual Event on January 8, 1982, plant instruments indicated
degraded filter performance and/or bypassing of the AB and FHB Ventilation
System.
Investigation and corrective action apparently were not initiated until
after NRC site staff questioned your staff on this matter. Contrary to Technical
Specifications, a determination of reportability for the event was not made
until March 3, 1982, and subsequent to a meeting with NRC site personnel on
March 2, 1982. Additionally, at the conclusion of this inspection period,
records were not available for many of the HEPA filter inspections and tests
performed by one of your contractors for various filter replacements in 1979 to
1980.
Another example of delayed corrective actions associated with these ventilation
systems is noted.
In our letter dated October 6, 1981, which transmitted NRC
Region I Inspection Report No. 50-320/81-15, we brought to your attention four
apparent violations of Technical Specification Operability and Surveillance
Requirements related to these ventilation systems.
In your letter dated January 25,
1982 you acknowledged two of the four violations and committed to a response
date for the remaining two items by February 5, 1982. Since these violations do
not constitute an immediate threat to public health and safety and in the interest
of assuring effective corrective action, this office granted an additional
extension for the responses on April 28, 1982.
Timely corrective action to
address these issues has not been apparent.
The operability of the ventilation systems for the Reactor Building, Auxiliary
Building and Fuel Handling Building is an important aspect when considering the
contamination of components housed within those buildings, as a result of the
March 28, 1979, accident.
We consider the apparent degradation of these venti-
lation systems to be a serious matter and believe that the management and procedure
controls associated with this problem need to be examined.
In light of your
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unique activity to safely decontaminate and defuel TMI-2, we have concluded
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GPU Nuclear Corporation
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JUN 2 2 1992
that a management conference is necessary as soon as possible.
At the conference, you should be prepared to discuss the circumstances surrounding
these matters, your immediate corrective actions, your views on the significance
of the problem and your findings on the adequacy of the control systems that
allowed these to occur.
In addition, you should also be prepared to discuss the
existing controls in your corrective actions system and contemplated irrprovements
for major decontamination activities, including the upcoming reactor core evalua-
tion activitics.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures
will be placed in the NRC Public Docunent Room unless you notify this office, by
telephone, within 10 days of the date of this letter and submit written application
to withhold information contained therein within 20 days of the date of this
letter.
Such application must be consistent with the requirements of 2.790(b)(1).
The telephone notification of your intent to request withholding, or any request
for an extension of the 10 day period which you believe necessary, should be
made to the Supervisor, Files, Mail and Records, USNRC P.egion I, at (215) 337-5223.
Your cooperation with us in this matter'is appreciated.
Sincerely,
original Si8n'd 878
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Richard W. Starostecki, Director
Division of Project and Resident
Programs
Enclosures:
1.
Appendix A, Notice of Violation
2.
NRC Region I Inspection Report 50-320/82-04
cc w/ encl:
L. King, Acting Director, Site Operations
J. E. Larson, Supervisor, TMI-2 Licensing
E. G. Wallace, PWR Licensing Manager
J. B. Liberman, Esquire
G. F. Trowbridge, Esquire
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
Ms. Mary V. Southard, Co-Chairman, Citizens for a Safe Environment
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(Without Report)
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Region I Docket Room (w/ concurrence)
L. Barrett, Deputy Program Director, TMI Program Office
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J. Goldberg, OELD:HQ
Chief, Operational Support Section'(wo/ enc 1)
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Ms. Mary V. Southard, Co-Chairman, Citizens for a Safe Envir~onment
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