IR 05000289/1985027
| ML20199A881 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/02/1986 |
| From: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| References | |
| NUDOCS 8606160087 | |
| Download: ML20199A881 (3) | |
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JUN 2M l
l Occket/ License No. 50-289/0PR-50 GPU Nuclear Corporation ATTN: Mr. H. D. Hukill Director and Vice President, TMI-1 P. O. Box 480 Middletown, Pennsylvania 17057
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Gentlemen:
Subject: NRC Inspection 50-289/85-27 This' letter is in response to your letters, dated February 10,19, and March 7, 1986, which collectively represent your response to a Notice of Violation issued by this office on January 9,1986. The corrective and preventive actions docu-mented in these letters are acceptable; however, we wish to clarify our position on certain matters and to acknowledge your editorial comments.
In regard to Part 1 of Violation A, dealing with the failure to establish pro-cedures, we note that as a matter of record you disagreed with the finding in your letter of February 10, 1986; but you provided adequate corrective and pre-ventive actions in a subsequent response, dated March 7, 1986. The ANSI 18.7-1976, paragraph 5.2.7, and subsequent draft revisions are-clear in requiring procedures for activities affecting quality.
For jobs involving skills nor-mally possessed, the procedure need not include step-by-step delineation, but the activity still must be under procedural control. Thus, we consider Part 1 of Violation A to be a valid citation.
Further, you stated that the subject individuals " acted appropriately in performing the operation as they did."
Yet, in one case, the activity caused a pressurizer safety valve tailpipe flow indicator to become inoperable, unexpectedly to the control room operators.
Our position is that, in assuring safe operation including the minimization of human error, the factors of (1) personnel training and qualification; (2) super-vision; and, (3) procedural controls must each be emphasized.
Failure to esta-blish procedures was also an underlying cause of a violation brought to your attention in NRC Inspection No. 50-289/85-19. Management attention to this matter is warranted to preclude additional recurrence of this violation. Your response to Part 2 of Violation A, dealing with the failure to properly change procedures is acceptable. We will continue to follow your actions related to procedure adherence which is a long standing issue at TMI.
Your response to Violation C, dealing with the failure to properly review for adequacy administrative control procedures on the independent verification of equipment control measures, is acceptable. Also, thank you for the clarifications listed on page 3, items a. to c. of your February 14, 1986, letter. We agree that the first item listed under the " contrary to the above" in the citation is somewhat unclear. Our intent in listing several procedure revisions was not to
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GPU Nuclear Corporation
imply that each revision changed _the scope of independent verification; we intended to show that the scope inconsistencies persisted through the revisions.
The program scope problem, identified internally by one of your review groups, was not highlighted sufficiently to management and was not effectively acted upon.
Because we feel that you now understand our position from discussions with your staff and from your proposed corrective actions, a revision to the Violation C will not be. issued.
Thank you for'your cooperation in this matter.
Sincerely, Original Signed Bya.
R. Starostecki, Director Division of Reactor Prcjects cc:
R. J. Toole, Operations and Maintenance Director, TMI-1 C. W. Smyth, TMI-1 Licensing Manager R. J. McGoey, Manager, PWR Licensing R. L. Blake, Jr.
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector (2 copies)
Commonwealth of Pennsylvania bec:
Region I Docket Room (concurrence copy)
J. Goldberg, OELD: HQ Management Assistant, DRMA (w/o encis)
A. Blough, RI W. Travers, NRR J. Thoma, NRR-C. Anderson, RI K. Abraham, RI R. Conte, RI I
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imply that each revision changed the scope of independent verification; we intended to show that the scope inconsistencies persisted through the revisions.
The program scope problem, identified internally by one of your review groups, was not highlighted sufficiently to management and was not effectively acted upon. Because we feel that you now understand our position from discussions with your staff and from your proposed corrective actions, a revision to the Violation C will not be issued. Further, based on your March 7, 1986, response, we also acknowledge that you are not invoking the backfit rule at this time regarding revisions to the independent verification program.
Thank you for your cooperation in this matter.
Sincerely, Crisinal Signed Byg*
R. Starostecki, Director Division of Reactor Projects cc:
R. J. Toole, Operations and Maintenance Director, TMI-1 C. W. Smyth, TMI-1 Licensing Manager R. J. McGoey, Manager, PWR Licensing R. L. Blake, Jr.
Public Document Room (PDR)
local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector (2 copies)
Commonwealth of Pennsylvania bec:
Region I Docket Room (concurrence copy)
J. Goldberg, OELD: HQ Management Assistant, DRMA (w/o encls)
A. Blough, RI W. Travers, NRR J. Thoma, NRR C. Anderson, RI K. Abraham, RI R. Conte, RI'
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GPU Nuclear Corporation Nuclear a::,orns::=
Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84-2386 Writer's Direct Dial Number February 10, 1986 5211-86-2019 Dr. Thomas Region I, Regional Administrator U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pa.
19406
Dear Dr. Murley:
Three Mile Island Nuclear Station Unit 1 (TMI-1)
Cperating License No. DPR-50 Docket No. 50-289 Notice of Violation Response for Inspection Report 85-27 Attachment A to this letter is GPUN's response to Appendix A of Inspection Report No. 50-289/85-27 " Notice of Violation" with the exception of part C which will be submitted by February 18, 1986 as discussed with R. Conte of Region I on February 10, 1986.
Sincerely, D.
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Director, TMI-1 HDH/MRK/spb l
cc: (W.~ Kane !!'
R. Conte Sworn and Subscribed to Before Me This /on Day 0485A of bh u og
, 1986.
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i l';;3'E10'.a E020. DAUPillN CCL,NTY MY C0!.!Ul5 'O.1 EXP:R:S JUNE 12. 1809 Me:nbar, Pennsylvania Association cf Notaries GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
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ATTACINENT A FINDING:
A.
Technical Specification 6.8.1 states, " Written procedures important to safety shall be established, [and] implemented... covering the...
applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February,1978...."
1.
Appendix A of Regulatory Guide 1.33, Revision 4, recommends that operation of the control rod drive system and the liquid radioactive waste system be covered by written procedures.
Contrary to the above:
a.
On October 23, 1985, an operation involving the overriding of the safety rods out interlock for the control rod drive system was
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conducted without the use of a written procedure; and b.
On November 1,1985, an oxygen sample was taken from the reactor coolant drain tank without the use of a written procedure.
This operation resulted in the inadvertent draining of one leg of differential flow transmitter 922, making this reactor coolant safety valve flow instrument inoperable until the leg was refilled later the same day.
2.
Administrative procedure 1001G, Revision 10, January 30, 1985,
" Procedure Utilization," paragraph 3.1.5 states, in part, that if the individual actually performing the activity cannot or believes he should not follow the procedure governing that activity as written, he shall place the system / component into a stable and safe condition and expeditiously inform the supervisor responsible (for resolution).
Contrary to the above:
a.
On November 1 and 6,1985, during the lineup for a liquid release from the waste evaporator condensate storage tank per operating procedure 1104-298, procedure steps 1.3.A, B, C could not be implemented as written and the supervisor was not contacted to resolve the discrepancy.
b.
On Novenber 12, 1985, the pre-inspection lineup for emergency diesel generator 1B could not be implemented as written and the supervisor was not contacted to resolve the discrepancy.
Collectively, items A.1 and A.2 represent a Severity Level IV Violation (Supplement I).
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RESPONSE:
A.
1.
GPUN disagrees with Finding A.l.
The two operations discussed in Finding A were performed by individuals qualified to perform these.
Guidance exists in the Operational Quality Assurance Plan, Sections 6.11.1.2 and 6.11.1.3 and Administrative Procedure AP 1001G,
" Procedure Utilization," Section 3.3.4, which allows qualified personnel possessing the appropriate skills to perform maintenance wort without step-by-step delineation in a written procedure.
Although we feel the individuals acted appropriately in performing the operations as they did, additional guidance will be provided for personnel performing troubleshooting maintenance activities.
A.
2.
Operating Procedure 1104-29S was incorrectly identified as Procedure 1104-298 in Finding A.2.a.
(1 ) Corrective Steps Which Have Been Taken As documented in Inspection Report 85-26, a procedure change request was initiated to correct the discrepancy identified in operating procedure OP 1104-29S.
Surveillance Procedure SP1301-8.2, " Diesel Generator Annual Inspection," will be revised to correct the discrepancy identified.
As requested in the cover letter to Inspection Report 85-27, the following corrective actions address the GPUN response to this finding and the actions taken to assure personnel understand the procedure control program, and the steps taken to assure implementation of the program.
Sufficient controls are in place in AP 1001 G to assure future procedure adequacy problems are identified and resolved prior to implementation.
The Director, TMI-1 discussed procedure compliance with Maintenance and Operations personnel during the timeframe of November 26 to December 30, 1985 as part of the corrective action for the response to the violation in Inspection Report 85-22. The discussions included the need to correct procedure deficiencies and discrepancies identified using the TCN and PCR systems.
In addition, Quality Assurance monitoring personnel are continuing, as part of the corrective action in IR 85-22, to document when procedures are found to be unable to be implemented as written.
These monitoring reports are provided to the Director.
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(2) Corrective Action That Will Be Taken No further action is considered necessary in addition to the actions described above.
The QA monitoring reports will be provided to the Director until he feels it is no longer necessa ry.
(3) Date When Full Compliance Is Achieved The controls in AP 1001 G have been discussed with personnel and are now being implemented, therefore, we feel compliance has been achieved. Any procedure deficiencies will be corrected as they are identified.
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FINDING:
B.
Technical Specification 6.5.4 establishes certain requirements for the Independent Onsite Safety Review Group (IOSRG).
Technical Specification 6.8.1 requires, in part, that procedures covering safety review activities be implemented. Facility procedure 6310-ADM-1010.01,
" Independent Onsite Safety Review Group Procedure - TMI-1," Revision 3, June 19,1985, also describes requirements to be implemented by 10SRG.
Contrary to the above, certain IOSRG requirements as set forth in Technical Specification 6.5.4 and facility procedure 6310-ADM-1010.01 were not implemented as evidenced by the following examples.
1.
Facility procedure 6310-ADM-1010.01 specifies that the periodic review functions of the 10SRG be performed on a selective and overview basis. The procedure also specifies that the Manager, Safety Review, determine the items for review and the schedules for evaluations and assessments to implement the periodic review requirements.
However, as of November 15, 1985, no schedule for evaluations and assessments to implement the periodic review requirements had been prepared by the Manager, Safety Review. As a result, no periodic review of the required functional areas had been performed.
2.
Technical Specification 6.5.4.6 requires that reports of evaluations and assessments of the functional areas requiring review by the 10SRG be prepared, approved and transmitted to the Nuclear Safety Assessment Director, TMI-1, and Nuclear Assurance Division Vice President, and the management positions responsible for the areas reviewed.
However, during the period of January 1984 to November 1985, reports were generated by 10SRG in the form of memoranda, but there was no indication of report approval and distribution of these reports was not in accordance with the technical specification distribution requirements.
3.
Facility procedure 6310-ADM-1010.01, step 4.4.2, requires, in part, that " Recommendations prepared by the 10SRG based on evaluations, assessments, and reviews... be approved by the Manager, Safety Review, and transmitted to the Nuclear Safety Assessment Department Director and the management positions, including the division director /vice president, responsible for the areas reviewed." Also, step 4.5.1 of the procedure requires, in part, that records,
... shall include... recommendations to management and the
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results of such recommendaticns."
However,10SRG records for the period January,1984 to November,1985 showed no method of approval of recommendations exists, recommendations are not always clearly identified, recommendations are not always transmitted as specified and results of recommendations are not maintained.
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Facility procedure 6310-ADM-1010.01, step 4.3.4 states, "The 10SRG shall review all safety evaluations involving unreviewed safety questions or technical specification changes and concur with safety evaluation conclusions or provide comments for resolution."
Step 4.5.2 of the procedure requires a safety review sheet, form 6310-ADM-1010.01 -03, be completed for each 10SRG review of safety evaluations involving technical specification changes.
However, between July 20, 1984, and October 31, 1985, seven technical s;,ecification changes were submitted to the NRC, but only two of those changes, technical specification change requests 141 and 146, had safety review sheets completed.
Collectively, items B.1 through B.4 represent a Severity 1.evel IV Violation (Supplement I).
RESPONSE:
B.
GPUN agrees in part with the findings cited in Violation B.
Certain aspects of the findings, however, are based on interpretations which we believe differ from the intent of TMI-1 Technical Specifications (T.S.)
6.5.4 and GPUN procedures. These are the procedure which iglements the safety review process (1000 ADM 1291.01) and the procedure which implements T.S. 6.5.4 (6310 ADM 1010.01).
The third paragraph of the cover letter for IP 85-27 appears to be confusing the objectives of the safety review process with the responsibilities of the 10SRG. This reflects the interpretation that the Independent Onsite Safety Review Group (IOSRG) is responsible for conducting thorough reviews of all TMI-1 procedures for clarity and adequacy.
T.S. 6.5.4.3 states that one of the periodic review functions of the IOSRG includes evaluation for technical adequacy and clarity of procedures important to the safe operation of the unit on a selective and overview basis.
It is IOSRG's responsibility to identify in its assessments and evaluations any problems of technical adequacy and clarity which may be generic to the procedure review process.
Procedural adequacy is the responsibility of the procedure owner, who is aided by the input, reviews, and approvals provided by the Safety Review Process (1000 ADM 1291.01) and various division implementing procedures.
It is not the responsibility of the 10SRG to thoroughly review all procedures for clarity and technical adequacy.
10SRG provides an additional level of review on a selective basis that is beyond the safety
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review process.
10SRG does not provide the functions of the Independent Safety Reviewer (ISR). We feel that this and other interpretive differences are what led to the negative statements about 10SRG performance in IR 85-27.
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At the time of the inspection, GPUN had not documented its interpretation of certain words in procedure 6310 ADM 1010.01. This appears to have caused some of the confusion which has resulted in this violation.
These ambiguities are discussed as follows:
(a) Schedule - The procedure states that the Manager, Safety Review determines the items for review and the schedules for evaluations and assessments to implement the periodic review functions.
It was never intended that schedules be drawn up or formalized.
In this context, the word " schedule" is used to show the degree of management control over IOSRG activities exercised by the Manager, Safety Review. The word " schedule" does not appear in T.S. 6.5.4.
(b) Periodic - T.S. 6.5.4.3 specifies the periodic review functions which must be conducted by IOSRG on a selective and overview basis.
These review functions are performed by 10SRG on a continuous basis.
Our method of accomplishing the periodic review functions had not been documented.
Improvements in this area will be accomplished pursuant to Section II.2 of the corrective action, (c) Reports - T.S. 6.5.4 requires that reports of evaluations and assessments of the functional areas requiring review by 10SRG be prepared, approved, and transmitted in a prescribed manner.
Reports of 10SRG evaluations and assessments in summary form have consistently been prepared, approved and transmitted as required by T.S. 6.5.4.
At the time of the inspection, G?UN had no documentation indicating that these are the only reports which are required by T.S. 6.5.4.
Another source of confusion was the fact that GPUN changed the frequency of these reports from monthly to bi-monthly and the procedure (6310 ADM 1010.01) had not been revised to reflect this change. Therefore, these reports were not being issued in accordance with the procedural requirements. Without clear definition that these reports were those intended to fulfill the T.S. requirement, one could interpret the word " report" to mean any memorandum prepared by any 10SRG member including file memoranda prepared simply to document background information in a retrievable i
form.
It is clearly not the intent of T.S. 6.5.4 that every l
memorandum prepared by a member of IOSRG be approved by the Manager, Safety Review and given a prescribed distribution.
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(d) Recomendations - The procedure (6310 ADM 1010.01) requires that recommendations prepared by the 10SRG based on evaluations, assessments and reviews be approved by the Manager, Safety Review, and transmitted in a prescribed manner.
T.S. 6.5.4.4 requires only that, based on its reviews, 10SRG provide recommendations to the management positions responsible for the areas reviewed.
All 10SRG correspondence during the period January 84 through November, 85 addressed to persons outside the group has been reviewed to determine the level of compliance with these requirements.
Based upon our review of these documents, we feel that the T.S. requirements have been met. However, the practice which has evolved for handling recommendations has not been made a part of the procedure. Whether or not the procedure has been violated depends on what constitutes a recommendation or simply may have been a question or concern that was answered or sufficiently addressed in some manner and did not need to be pursued by the 10SRG. We believe that the intent of the procedure has been met.
Documentation was reviewed for all technical specification changes submitted to NRC between July 20, 1984 and October 31, 1985 to determine whether reviews were conducted by 10SRG. We found the documentation to verify that the IOSRG reviewed all of these submittals. However, completion of 5 out of 7 of these reviews was not appropriately documented using the form required by the procedure.
Improvements in this area will be accomplished pursuant to Section II.6 of the corrective action.
GPUN believes that the violation and findings as described in IR 85-27 are to a large extent the result of inadequate procedural guidance which has caused inconsistencies, lack of uniformity, and/or lack of adequate documentation. The lack of adequate documentation to demonstrate the level of compliance actually achieved has contributed to the perceived poor performance of IOSRG as concluded by IR 85-27. We feel that the improvements described below will accomplish the required corrective i
action.
I.
Corrective Steps Which Have Been Taken and the Results Achieved GPUN has reviewed 10SRG activities and practices demonstrated through the group's correspondence, documentation, and follow-up tracking system in order to determine the adequacy of the procedure and practices as well as the level of compliance with the procedure and T.S.
Each of the findings described in the violation and discussed in other sections of IR 85-27 has been examined to determine what changes are needed in order to comply with the requirements and improve the consistency and quality of documentation used to demonstrate compliance.
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II. Corrective Steps Which Will Be Taken To Avoid Further Violations Revision of the 10SRG procedure (6310 ADH 1010.01) was in progress but incomplete at the time of-the inspection. As a result of the reviews and discussions which have taken place to address the IR 85-27 findings in the area of the 10SRG, improvements in the practices and procedure of the 10SRG are still in progress.
Some of these improvements which will be taken to avoid further violations dre as follows:
(1 ) Procedural clarification so that use of the word " schedule" is unambiguous.
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(2) An administrative procedure will be written to describe and document the periodic reviews performed by IOSRG.
(3) Procedural clarification to specify which reports are those that satisfy T.S. 6.5.4.6 requirements for reports of the 10SRG evaluations and assessments.
(4) Procedural clarification to specify the appropriate distribution for IOSRG correspondence.
(5) Procedural clarification to ensure uniformity and consistency in the documentation and handling of 10SRG recommendations.
(6) Procedural clarification to ensure uniformity and consistency in the documentation and handling of 10SRG's reviews of safety evaluations involving unreviewed safety questions or technical specification cha nges.
III. Date When Full Compliance Will Be Achieved Procedure 6310 ADM 1010.01 will be revised to incorporate the necessary changes. This revision will be completed by April,1986.
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' FINDING:
D.
The Three Mile Island Nuclear Station, Units 1 and 2, Modified Amended Physical Security Plan requires, in part, that all personnel in protected and vital areas display their photo identification badges. Technical Specification 6.8.1.d requires, in part, that written procedures be implemented covering security plan implementation.
Security procedure 1005.11. " Access to Protected / Vital Areas," Revision 36, dated July 29, 1985, states in part that all personnel entering THI-l protected areas shall display their photo identification badge except under certain specified conditions that permit the badge to be removed and secured in the owner's pocket.
Contrary to the above, on November 15 and 18,1985, photo identification badges and keycards were found attached to garments on a rack at an unattended changing station, and therefore were not on the individuals.
Further, between November 20 and 27,1985, certain employees were in the instrument and control shop and the control room and their photo identification badges were not displayed or secured in their pockets.
This is a Severity Level V Violation (Supplement III).
RESPONSE:
1.
Corrective Steps Which Have Been Taken and Results Achieved During the period of December 2,1985 to December 20, 1985, the Director, TMI-l discussed the proper wearing of the Protected Area badge with perso nnel. This has also been discussed in one of the Director's Site Managers meeting.
In addition, guidelines for wearing a Protected Area badge, including the circumstances when it is acceptable not to display the badge, were distributed to all badge holders.
2.
Corrective Steps Which Will Be Taken to Avoid Further Violations No further action is planned beyond instructing personnel on proper wearing of badges as part of annual general employee training.
3.
Date When Full Compliance Will Be Achieved With the completion of the above corrective actions, compliance has been achieved. However, we see this as being a potentially reoccurring problem due to unintentional noncompliance.
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GPU Nuclear Corporation U Nuclear
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Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number February 19, 1986 5211-86-2027 Dr. Thomas Region I, Regional Administrator U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pa.
19406
Dear Dr. Murley:
Three Mile Island Nuclear Station Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Notice of Violation Response for Inspection Report 85-27 Attachment A to this letter is GPUN's response to Violation C of Appendix A to Inspection Report No. 50-289/85-27 " Notice of Violation." This response is being submitted late as discussed with NRC resident inspectors R. Conte and
j F. Young.
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Sincerely, H. D. Hu ill Director, TMI-1 HDH/MRK/spb:0491A
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Attachment cc:
W. Kane t
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R. Conte l
Sworn and subscribe # o dt i
before me this /9 day of /&AraAev 1986.
ATA dA/L Y
Notary PUDl1C g;f CetSTANCE E. EtRGEL. NOTAW PUBUC BIODLETOWS BORD DAUPHIN C0Gil1Y 57 Counts:let IIPlats MARCH 20.19st
%%. ^vi."SMA1151Ms a subsidiary of the General Public Utilities Corporation
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Attachment A FINDING:
l C.
-Technical Specifications 6.5.1.1 and 6.8.2 require, in part, that changes to safety-related administrative control procedures be reviewed for adequacy.
Contrary to the above, between September 5,1984 and Novenber 27, 1985, changes (revisions) were made to several safety-related administrative control procedures (AP) dealing with independent verification of safety-related activities, and these changes were not completely reviewed for adequacy in that:
Seve.al APs required independent verification for a scope of equipment
less than safety-related as reflected in the staff's safety evaluation report (NUREG 0680, Original Supplement, page C2-5) or as required by TMI - Task Action plan Item I.C.6 (NUREG 0737).
(These APs were AP 1001 A, Revision 9, June 3,1985, " Procedure Review and Approval;"
AP 1001J, Revision 3, January 3,1985, " Technical Specification Surveillance Testing Program;" AP 1002, Revision 36, October 14, 1985,
" Rules for the Protection of Employees Working on Electrical and Mechanical Apparatus;" and AP 1029, Revision 20, November 12, 1985,
" Conduct of Operation."
Administrative procedure 1003, Revision 17, dated October 23, 1985,
" Bypass of Safety Function and Jumper Control," requires independent verification for important to safety systems without updating this requirement into subtier operating, survei' lance, and maintenance procedures dealing with important to safety systems such as the liquid waste disposal system.
This is a Severity Level IV Violation (Supplement I).
RESPONSE:
GPUN agrees in part with this violation in that review and approval of AP 1013, Revision 17, conducted pursuant to T.S. 6.5.1.1 and 6.8.2, resulted in inconsistencies with some of the subtier procedures. However, we differ in regard to certain basic aspects of the violation and some of the supporting statements presented in others sections of the Inspection Report (IR 85-27).
To a certain extent, the violation appears to be based on the assumption that NUREG 0737, Task Action Plan (TAP) Item I.C.6 imposes a stricter requirement for independent verification than was originally intended and that GPUN made commitments toward a broader scope of independent verification than was actually made. We believe that this violation reflects a new interpretation of NRC requiremer.ts and/or GPUN commitments.
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-2-Clarification of NUREG 0585, Recommendation 5, "Verifica: ion of Correct Performance of Operating Activities" was provided in NUREGs 0660 and 0737, Item I.C.6 " Guidance on Procedures for Verifying Correct Performance of Operating Activities." Licensees were required to review and revise procedures as necessary to ensure an effective system of verifying the correct performance of operating activities.
An acceptable program for verification of operating activities was described, however in this context other specific programs might also be acceptable.
GPUN's response to NUREG 0737 included a response to Item'I.C.6 as references to specific commitments in our Restart Report which addressed the requirement of NRC's Order dated August 9,1979. Our commitment to independent verification included only the ESAS and EFW systems. These commitments were expressed not only in our correspondence but also in testimony during the heari ngs. The staff's safety evaluation report (NUREG 0680, Original Supplement, page C6-4) also references our commitment accurately.
NRC's acceptance of these commitments was documented following its post implementation review.
NRC closed out TAP I.C.6 in Inspection Report 82-16 dated October 5,1982 and opened a new item regarding the implementation and documentation of independent verification. That open item was closed out concluding that independent verification was acceptable. Therefore we believe that this violation represents a new interpretation of a previously accepted staff position.
It appears that the reference to page C2-5 of the Restart Report SER (NUREG 0680) is inappropriate and taken out of context. The question responded to on that page clearly addresses EFW valves and safety related valve positions to ensure proper operation of engineered safety features.
In response to a statement on page 46 of the Inspection Report, we are not aware of any occasion where GPUN representatives committed to or led the NRC staff to believe that independent verification of component positioning (valves and switches) subsequent to maintenance and testing would be accomplished for a broader scope of safety related components.
The Inspection Report (page 2, Inspection Results) provides NRC concurrence that TMI-1 Restart Hearing commitments have been met.
Inspection Reports 82-16 and 83-02 confirm NRC acceptance of the adequacy of TMI-l compliance with NUREG 0737, Item I.C.6 on independent verification. GPUN's program for independent verification has not decreased in scope subsequent to NRC approval. Therefore, we do not believe that operation in accordance with our current commitments to independent verification constitutes a violation of NRC requirements.
At the NRC's request, we have committed to reevaluate our commitments toward TMI Task Action Plan (TAP) Item I.C.6 and to provide a restatement of the independent verification program and our commitments to HRC by April 1,1986 as discussed with the NRC senior resident inspector on February 19, 1986.
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-3-a GPUN desires to comment on other details presented in IR 85-27 where our understanding differs somewhat from NRC's findings. These are as follows:
a.
The Inspection Report stated that between September 5,1984 and Novenber 27, 1985, changes (revisions) were made to several
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safety-related administrative control procedures dealing with independent verification of safety-related activities.
It was implied that this
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included Revision 9 to AP 1001 A, Revision 3 to AP 1001J, Revision 36 to
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AP 1002, and Revision 20 to. AP 1029. Changes made in these revisions however had nothing to do with independent verification. The only revision to an AP that dealt with this subject was AP 1013, which was revised to broaden the scope of verification required rather than to reduce the scope. If it is implied in Inspection Report 85-27 that changes to TMI-1 procedures have reduced the scope of independent verification during the period of time referred to, it should be pointed
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out that no such changes have been made to reduce the scope of independent verification,
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b.
Section 7.4 of the Inspection Report states that a step in one of the procedures calling for verification of redundant component operability when taking equipment out of service included not only ESAS and EFW, but also RPS and RMS. The Inspection Report implies that this represents an i
inconsistent definition of ESAS.
Our commitments on independent verification provided in our letter of November 8,1979 specifically addressed RPS and RMS in addition to ESAS and EFW but only to the extent of supervisor verification of the documentation. We do not believe that inclusion of additional systems into this commitment or any procedural requirement clouds the definition of ESAS.
Nor do we feel that there
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should be any confusion in regard to those systems or components which receive an ES actuation signal simply through variations in use of the ESAS acronym.
l Engineered Safeguards is defined in Chapter 6.0 of the FSAR. The terms j
" Emergency Safeguards Actuation System" or " Safety Features Actuation l
System (SFAS)" have been used occasionally in place of the proper expression, " Engineered Safeguaads Actuation System (ESAS)." We do not feel that any of these terms should be confusing to anyone who is knowledgeable about TMI-1 systems.
c.
Inspection Report 85-27 states that Revision 17 to AP 1013 was responsive to a recommendation from 10SRG (but not timely or effective). However, l
the referenced memorandum, prepared by a member of 10SRG, was addressed only to his manager. We are not aware of this recommendation ever having i
been issued as a recommendation by the IOSRG.
It is our understanding that the changes to AP 1013 in Revision 17 may have been prompted independent of the 10SRG.
Subsequent to the referenced memorandum, in response to the NRC IE Information Notice 85-51 which dealt with Independent Verification,10SRG concurred with the current TMI-1
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independent verification program and referenced NRC acceptance of the l
program and its implementation. Therefore, these changes should not be viewed as corrective action in response to an IOSRG recommendation since
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such a recommendation was not issued.
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-4-The procedural change which resulted in inconsistencies in our independent verification program was Revision 17 to AP 1013, not AP 1003 as referenced in the Inspection Report.
Revision 17 to AP 1013 " Bypass of Safety Functions and Jumper Control" broadened the administrative controls over lif ted leads and jumpers from independent verification of Nuclear Safety Related (NSR) systens to a scope which includes Important To Safety (ITS) systems. The inconsistency arose when this change was reviewed and approved without providing for the update of the lower tier procedures which were affected.
This oversight caused inconsistencies between AP 1013 and some of the subtier operating, surveillance, and maintenance procedures which still need to be revised to reflect this new scope.
Out of the large number of procedures that could have steps that might be affected, only a few inconsistencies have been i dentified. It will require a complete cycle of the detailed periodic procedure review process to ensure that any other inconsistencies are i dentified.
I.
Corrective Steps Which Have Been Taken and Results Achieved Procedural changes to provide consistency of subtier procedures with AP 1013 are in progress.
l II. Corrective Steps Which Will Be Taken To Avoid Further Violations i
We intend to provide a clear philosophy of the circumstances requiring independent verification and provide any needed improvements in what has been for the most part a very effective program.
Supervisors will review
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the independent verification program with all operations and maintenance personnel.
i Procedural changes to eliminate those inconsistencies between AP 1013 and the lower tier procedures, which have been identified, will be implemented by May,1986. Procedure owners will be advised to look for any additional inconsistencies and make any necessary changes during the periodic procedure review process.
In order to avoid further violations of this type in the future, GPUN will emphasize to the members of the plant review group the need to thoroughly review all procedure changes for their potential impact on other procedures.
III. Date When Full Compliance Will Be Achieved Although we have committed to reevaluate GPUN commitments on independent j
verification, we do not feel that the company is in violation of our l
commitments or NUREG 0737, Item I.C.6 requirements.
With the exception of the review of all procedures, the actions described i
in section II to achieve compliance will be completed by May,1986, i
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e GPU Nuclear Corporation j
Post Office Box 480 g
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Route 441 South Middletown. Pennsylvania 17057-o191 717 944-7621 TELEX 84 2386 Writer's Direct Dial Number:
March 7, 1986 5211-86-2043 Dr. Thomas Region I, Pegional Administratnr U.S. Nuclear Regulatory Commission l
631 Park Avenue i
King of Prussia, PA 19406
Dear Dr. Murley:
Three Mile Island Nuclear Station Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Clarification of Notice of Violation Response for Inspection Report 85-27 On February 27, 1986, GPUN met with R. Conte and R. Blough of NRC Region I to discuss our Notice of Violation response for IR 85-27, submitted February 10 and 19,1986. As a result of that meeting, we offer the following as clarification of our response to parts A, C and D of the Notice of Violation:
A.
Part 1.
Administrative guidance is being provided for personnel performing evolutions not covered by written procedures that is similar to what is contained in Section 6.11.1.3 of the Operational Quality Assurance Pl a n.
This guidance will be incorporated into procedures AP 1001G,
" Procedure Utilization" and AP 1029, " Conduct of Operation." This information will be disseminated to TNI-1 personnel by memo from the Director, TMI-1.
C.
We understand that it was not the NRC's intent in its statement of Violation Part C to cite GPUN against our commitments on independent verification or against NUREG-0737, Item I.C.6 requirements.. Therefore, we do not view Part C of the violation as a backfit. However, GPUH has committed voluntarily to re-evaluate its commitments toward Item I.C.6 and provide NRC with a restatepent of the independent verification program by April 1,1986. We believe that the NRC will find our commitment revalidation acceptable. However, the NRC should not view this voluntary h
effort as relinquishing our rights under the backfit rule with respect to this issue.
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GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
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March 7, 1986 5211-86-2043-2-i D.
We believe clarification of the compliance portion of our response to Part D is needed. We feel compliance has been achieved with the completion of our corrective actions.
However, we see this as an item that will require continued supervisory attention to ensure continued complia nce.
Sincerely, t
. D. H ill Director, TMI-1 HDH/MRK/spb 0522A cc:
R. Conte W. Kane Sworn and subscribed to before me this %
f day of % gl, _ _,1986,
h irt Y-ElY
,7 Notary Pubfic SMROM P. E?.CWN. NOTARY PU6L!C
"iODtiMW'! C00. DAUPH!N COUhiY fiY Ct!'fi;12t E!?fil3 JUNE 12.190 thet:. ?c.ssytr.r.t: As:cciadca ei lfc: sties s
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