IR 05000289/1986024
| ML20212B563 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/15/1986 |
| From: | Anderson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20212B509 | List: |
| References | |
| 50-289-86-24-EC, NUDOCS 8612290273 | |
| Download: ML20212B563 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 86-24 Docket No. 50-289 License No. DPR-50 Category C Licensee: GPU Nuclear Corporation P.O. Box 480 Middletown, Pennsylvania 17057 Facility Name: Three Mile Island 1 Meeting At: King of Prussia, PA Meeting. Conducted: December 4, 1986 Prepared by:
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M C. 4( Anderson, Chief date Plant Systems Section, EB, DRS Meeting Summary: Enforcement Conference at NRC Region I on December 4, 1986 to discuss the findings of an investigation conducted by the Office of Investigation (OI), Case Number 1-84-021,concerning deficiencies in the Equipment Qualification (EQ) Program at Three Mile Island, Unit 1, during the period 1981-1984.
The findings included inadequate response to internal Quality Assurance identified deficiencies in the EQ program and inaccurate reporting of the status of the TMI-1 EQ program to the NRC. The licensee presented their position relative to the findings.
In addition they discussed the root causes of the problems and corrective actions.
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8612290273 B61218 PDR ADOCK 05000289 G
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Details 1.
Participants GPU Nuclear Corporation (GPUN)
P. R. Clark, President R. F. Wilson, Technical Director R. W. Keaton, Director of Quality Assurance T. A. Baxter, Attorney (Shaw, Pittman, Potts & Trowbridge)
R. McGoey, Licensing
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T. F. Mancinelli, Manager, EQ and Fire Protection State of Pennsylvania A. Bhattacharyya USNRC T. Murley, Regional Administrator J. Allan, Deputy Regional Administrator J. Gutierrez. Regional Counsel W. Kane, Director, Division of Reactor Projects W. Johnston, Deputy Director, Division of Reactor Safety J. Durr, Chief, Engineering Branch, DRS A. Blough, Chief, Projects Branch 1, DRP D. Holody, Enforcement Specialist, RI R. Holler, Enforcement Specialist, IE J. Thoma, Project Manager, NRR R. Conte, Chief, Reactor Project Section 1A, DRP S. Young, Senior Resident Inspector G. Napuda, Reactor Engineer, QA Section, DRS C. Anderson, Chief, Plant Systems Section, DRS 2.
Purpose This enforcement conference was held at the request of NRC Region I to discuss the findings of an investigation conducted by the Office of Investigation (OI) concerning deficiencies in the Equipment Qualification (EQ) Program at Three Mile Island, Unit 1, during the period 1981-1984.
Issues to be discussed at the conf-+once included:
1) Inadequate response
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by the Technical Functions departet to the EQ deficiencies identified by
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an internal Quality Assurance audit in 1981; inaccurate letters from the licensee to the NRC indicating that TMI-1 was in compliance with EQ program requirements, even though QA audits indicated numerous deficiencies; and 3) a poor interface between the Technical Functions department, the QA department and the GPU licensing organization. The discussion was to include the licensee perspective or the issues; the root cause of the deficiencies and corrective actions.
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Presentation and Discussion Following the initial introductions, the meeting was opened by the Regional Administrator followed by'the Deputy Director, Division of Reactor Safety.
The purpose of the meeting was discussed.
The President of GPU provided a general response to the NRC concerns. He indicated that during the 1981-1984 period the TMI-1 EQ program was not handled properly. There were deficiencies in both the Technical Functions department and the Quality Assurance department which contributed to the problems. The licensees meeting agenda was presented. A copy of the agenda is attached. A chronology of major EQ milestones was reviewed. A copy of the chronology is attached.
The Technical Director discussed Item II on the agenda, bases for the letters to the NRC. He indicated that the letters reflected their understanding of EQ requirements at the time the letters were sent.
Thc.irector of Quality Assurance discussed Item III on the agenda, QA audit and ossessment. He briefly reviewed the general conduct of an audit and the closeout of audit items based on GPU procedures in place during the time of the problem. He also discussed their followup to the March 1981 audit.
In June 1981, the Technical Functions department discussed their handling of the
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QA findings with the QA department. This initial response was rejected by the QA department. However, Technical Functions revised actions were later accepted by QA. By May 1982, 25 of the 33 deficiencies had been closed out.
Approximately three (3) of the remaining open items were programmatic in nature., All of the audit deficiencies were closed by the end of 1984.
The second review of the EQ program by QA in January 1984 was not a formal QA audit subject to the GPU formal audit procedures.
It was an informal review of the EQ program requested by the Technical Functions department.
The formal exit for this second review was held in May 1984. The results of the second review were not available at the time the February 1984 GPU letter was sent to the NRC indicating TMI-1 compliance with EQ requirements.
With regard to QA escalation of the issues, it was noted that during the 1981-1984 period the QA Director was directly involved in assessing the adequacy of the corrective actions. Considering that work was going on to correct the deficiencies and that there was not unanimity in the QA department regarding the EQ deficiencies, it was concluded within the QA department that no further escalation was required.
The Technical Director discussed agenda Item IV, Effect of Open Audit Findings on Tech Functions approval of the letters. He indicated that had all the March 1981 audit findings been closed promptly, the deficiencies in the EQ program would have been reduced but not eliminated.
This was because at GPU:
1) individuals believed the items were closed out or 2) individuals thought the deficiencies were adequately addressed or 3) some individuals were not aware of the findings. The review process associated with the release of the subject letters to the NRC was briefly discussed.
It was noted that the QA department is not normally expected to concur in letters sent to the NRC.
Consequently, they were not requested to concur in the subject letters. A meeting was held with the NRC in October 1983.
It was indicated that this meeting provided the basis for the February 1984 GPU letter to the NR.-
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The Technical Director discussed Item V on the agenda, GPUN Root Cause Analysis. The root causes of the problems were attributed to five (5) items:
(1) There was inadequate prioritization of GPU resources. GPU did not appreciate the scope of the problem. As of August 1981, GPU believed they were on top of EQ issues.
(2) The EQ Supervisor did not perform adequately.
(3) There was a lack of understanding of NRC requirements by the EQ group.
(4) There was inadequate supervision'of the EQ group by Tech Functions management.
(5) The QA department did not pursue escalation within the organization.
The Technical Director discussed agenda Item VI, Actions Taken or Planned to Prevent Recurrence. The corrective actions in Tech Functions included the following:
There is now a different EQ supervisor - better leadership.
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GPU formed an engineering assurance department.
There is now improved GPU management attention to this area.
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Instructions have been provided to Tech Functions personnel regarding
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responses to QA findings and required actions.
The overall staff size has increased since 1981 - 1983.
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There are more indepth technical reviews of contractor reviews by GPU
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internal engineering.
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GPU has changed the primary signature responsibility for NRC letters so that the primary responsible group must now sign.
Licensing signature is always required.
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GPU must determine the group / individual input required for each response.
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l There are improved GPU guidelines regarding their consideration of EQ
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audit findings.
l The QA Director discussed corrective actions in the Nuclear Assurance area.
These include:
I Increased clarity regarding audit findings - some findings were not
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clear.
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There has been a reduction in the total number of audit findings. At the same time, the number of audits has increased. This has resulted in an improvement in improved timeliness in closing audit findings.
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Formal audit exits involve higher levels of management.
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There is better reception to QA audits.
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The procedures for escalating problem audit findings have been changed to assure timely resolution of problem areas and management attention to potential problems.
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There is now a greater tendency within GPU to escalate issues.
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Communications between the QA department and the Tech Functions department have been improved.
The President of GPU discussed agenda Item VII, Meaning of the Letters to the NRC. He indicated that the NRC should look at the subject letters in their entirety. While some of the statements in the letter indicate that TMI-1 was in compliance at the time, other information in the letters indi-cates that they were not in full compliance.
Each of the two letters contained inconsistencies regarding TMI-1 compliance with EQ requirements.
Summary statements by the President of GPU were that GPU now recognizes there were deficiencies in both the Tech Functions department and the QA department handling of the EQ audit findings. GPU has identified the root cause of the problems and has taken action in an attempt to correct the identified problems.
It was noted that, at the time of the problem, the plant was in cold shutdown.
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Concluding Remarks NRC management thanked the licensee for their presentation and stated that the information presented would be considered in the related NRC enforcement actions.
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Introductiori II.
Bases for the Letters to the NRC (May 20, 1983 and Feb. 10, 1984)
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QA Audit and Assessment IV.
Effect of Open Audit Findings on Tech Functions Approval of the Letters V.
GPUN Root Cause Analysis VI.
Actions Taken or Planned to Prevent Recurrence VII.
Meaning of the Letters to the NRC VIII.
Conclusion
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Background Major EQ Milestones
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1/14/80:
NRC issues IE Bulletin 79-01B, with attached DCR Guidelir.as and NUREG-0588 2/80:
Contract by GPUN with EDS in response to 79-01B 5/23/80:
Commission issues Memorandum and order adopting requirements and setting compliance schedules 3/24/81:
NRC issues TMZ-1 SER 8/28/81:
EDS work product submitted to NRC
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l 12/10/02: NRC issues TMI-l SER Iwith TER)
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2/22/83:
10 CFR 50.49 effective, with new compliance schedule 5/20/83:
GPUN letter
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10/5/83:
GPUN/NRC meeting on TER
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2/10/84:
GPUN letter 3/20/84:
NRC Audit begins Spring '84 GPUN Management recognised problems in EQ program 1/29/85:
NRC Audit begins 4/18/85:
NRC issues TMI-1 SER, finding compliance with 50.49
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