ML20030D065
| ML20030D065 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/25/1981 |
| From: | Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Hovey G METROPOLITAN EDISON CO. |
| Shared Package | |
| ML20030D066 | List: |
| References | |
| NUDOCS 8108310351 | |
| Download: ML20030D065 (3) | |
See also: IR 05000320/1980017
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U,NITED STATES
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NUCLEAR REGULATORY COMMISslON
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REGION 8
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631 PARK AVENUE
xima or Pnuss: A, PENNSYLVANI A 19406
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Docket No. 50-320
Metropolitan Edison Company
ATTN: Mr. G. Hovey
Vice President and Director TMI-2
P.O. Box 480
Middletown, PA 17057
Gentlemen:
Subject:
Inspection 50-320/80-17
This refers to your letter dated May 5,1981, in response to our letter
dated March 20, 1981 and a subsequent meeting held on June 1,1981,
between you and members of your staff and members of the Three Mile
Island (TMI) Resident Section of this office.
Your letter of May 5,1981,
contested items B(1) and B(2) in the notice of violation attached to our
letter of March 20, 1981.
Regarding item B(1), Operating Procedure (0P) 2104-4.13, Revision 7, was
dated September 10, 1980, at the top of the cover sheet. This was the
date on which the Unit 2 Superintendent (Director Site Operations)
approved the procedure.
The Master Procedure Index required by Adminis-
trative Procedure 1001, Section 3.7, listed September 10,1980, as the
revision date of OP 2104-4.13, P.evision 7.
Your response indicated that
this procedure was not implementad on October 3,1980, because a controlled
copy was not distributed to the Unit 2 Control Room.
The discussions of June 1, 1981, revealed that controlled copiet of
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0P 2104-4.13, Revision 7, were distributed to some control stations
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prior to October 3,1980, but not to the Unit 2 Control Room.
Furth ,,2 eq'
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additional internal review took place after approval by the Director',
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Site Operations and that no implementation date was identified fore' il A
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OP 2104-4.13, Revision 7.
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This procedural inadequacy remains and requires corrective action.
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8108310351 810625
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PDR ADOCK 05000320
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JUN 2 51981
Metropolitan Edison Company
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Based on the additional information you provided, we concur item B(1) is
not a verbatim violation of the requirements as stated; rather it is
an apparent violation in the area of document control, as required by
10 CFR 50, Appendix B, Criterion VI; Quality Assurance Plan, FSAR
Section 17.2.11 which requires in part that the Unit Superintendent
(Director Site Operations):
... provide in their procedures... measures...
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to ensure documents are available when required... changes be promptly
transmitted for incorporation into documents... ensure obsolete or superseded
documents are eliminated from the system and not used...."
Similar
requirements are reiterated in your effective Recovery Quality Assurance
Plan.
Based on a review of AP 1001, Revision 23, February 16, 1981, it appears
measures'are not established to control revised procedures from the date
of Director Site Operations signature to the date when revised procedures
become available for field use.
Further,this time period has been, in
our opinion, excessive.
The meeting of June 1,1981, indicated that you are taking the following
corrective actions.
The order of review and approval on operating procedures will
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be changed such that the Director Site Operations will be the
last individual to review and approve a procedure.
Effective dates will be established for procedures; this will
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allow time for distribution after final approval.
Three categories of procedures will be established as follows:
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Official copies - there are to be three copies of these,
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one each in the Unit 2 Control Room, library, and technical
support center.
Controlled copies - these will be distributed via the
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normal controlled copy distribution.
Uncontrolled copies - these will be used for information
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purposes only.
Field copies of procedures will be verified against official
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copies prior to performing the procedure.
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Metropolitan Edison Company
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JUN 2 51981
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Regarding item B(2) of the notice of violation, Attachment III to
0P 2104-4.13, Revision 6, stated the following:
"I. Purpose. The
purpose of this procedure is to identify a proper method for the N-100S
Series shielded transport cask 1.id. and shield plug hold-down stud
torquing.
II. Policy. The proper torquing of cask lid studs and shield
plug studs on the HN-100S Series cask is the responsibility of the
equipment user."
Your letter of May 5,1981, indicated that removal of the shield plug
was not necessary for operational purposes or for inspection of the
shield plug and thus the stud torquing sequence (Section IIIB) of the
procedure was not invoked.
Section IIIB provided a method of assuring and documenting that the
shield plug hold-down studs were properly torqued in accordance with
your quality assurance program.
No documentation of the proper torquing
of the shield plug hold-down studs was presented at the meeting on
June 1, 1981.
Accordingly item B(2) remains a violation.
Based upon information provided at the meeting on June 1,1981, we note
that you vill take apart and retorque the shield plug studs unless your
own (licensee) seal remains on the shield plug (indicating proper
torquing of the studs),
Further,it is our understanding that these
measures are incorporated into a later revision of OP 2104-4.13.
These corrective actions and measures to prever,t recurrence will be
examined during a future inspection of your licensed program. With
respect to item B(1),please respond within 20 days of receipt of this
letter indicating a date when your measures to prevent recurrence will
be effective.
Further in your subsequent response, please identify
misunderstandings presented herein,1f any.
Your cooperation with us is appreciated.
Sincerely,
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R. R. Kei
ig,
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Projects / ran
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Resident and Project Inspection
cc w/ encl:
J. J. Barton, Director, Site Operations
E. D. Fuller, TMI-2 Licensing Supervisor
E. G. Wallace, PWR Licensing Mana.ger
J. B. Liberman, Esquire
G. F. Trowbridge, Esquire
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