IR 05000289/1987004
| ML20207S571 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/04/1987 |
| From: | Blough A, Conte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20207S568 | List: |
| References | |
| 50-289-87-04-MM, 50-289-87-4-MM, NUDOCS 8703200047 | |
| Download: ML20207S571 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-289/87-04 Docket No.
50-289 License No.
DPR-50 Priority --
Category C Licensee:
GPU Nuclear Corporation 100 Interpace Parkway Parsippany, New Jersey 17057 Facility At:
Three Mile Island Nuclear Station, Unit 1 Inspection At:
Middletown, Pennsylvania Inspection Conducted:
February 12 and 18, 1987 Inspectors:
R. Conte, Senior Resident Inspector (TMI-1)
F. Young, Resident Inspector (TMI-1)
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3[4!87 Reviewed By:
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R. Conte, Senior Resident Inspectpr (TMI-1)
Date
_3/4/87 Approved By:
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A. Blough, thidf s
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Reactor Projects Section 1A J
Division of Reactor Projects Summary:
A meeting was held on February 12, 1987, at the NRC Region I Office in King of Prussia, Pennsylvania, between representatives of GPU Nuclear and the NRC staff to discuss GPUN's revised technical and safety review program and the findings of the licensee's Procedure Compliance Task Group. A followup
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inspection occurred on February 18, 1987, at the Corporate Office.
t Results:
The meeting and subsequent inspection were beneficial in mutually enhancing t
each party's understanding of related issues. Tt9 licensee made a number of
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commitments to enhance the guidance provided for and documentation of safety reviews. The final NRC staff disposition of findings associated with the technical and safety process will occur in a future inspection.
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DETAILS
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Attendees and Participants The following licensee and NRC staff personnel attended the meeting.
The Commonwealth of Pennsylvania sent a representative as an observer.
GPU Nuclear Corporation (GPUNC)
P. Clark, President of GPUNC R. Germann, Manager, Nuclear Safety, Corporate R. Long, Vice President of Nuclear Assurance R. McGoey, Manager of PWR Licensing M. Nelson, Manager of Nuclear Safety, TMI-1 C. Smyth, THI-1 Licensing Manager R. Toole, Operations and Maintenance Director, TMI-1 P. Wells, Nuclear Safety Assessment Engineer R. Whitesel, Nuclear Safety Assessment Director Nuclear Regulatory Commission W. Baunack, Project Engineer, Region I (RI)
A. Blough, Chief, Reactor Projects Branch No. 1, RI'
R. Conte, Chief, Reactor Projects Section No. IA, RI P. Eapen, Chief, Quality Asstrance Section, RI W. Kane, Director, Reactor Projects Division J. Thoma, Operating Reactors Project Manager, Office of Nuclear Reactor Regulation (NRR)
J. Wechselberger, Resident Inspector (0yster Cre d), RI F. Young, Senior Resident Inspector (TMI-1), RI Commonwealth of Pennsylvania A. Bhattacharyya (Observer)
2.
Purpose and Scope of the Management Meeting The purpose of this meeting was for the licensee to express their views on the NRC staff concerns and issues addressed in NRC Inspection Report No.
50-289/86-17.
These concerns centered on the adequacy of the licensee's technical and safety review process, apparent improper implementation of that program, and on recurrent procedure nonadherence problems. These issues were also identified in the previously completed reports documen-ting the Performance Appraisal Team (PAT) inspections and Systematic Assessments of Licensee Performance (SALP's) for the last yea c'
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Discussion
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3.1 Introduction
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The meeting started at 10:00 a.m. and lasted t k.11 noon. Attendees and participants are listed above. The licensee provided a brief agenda (attached) as a basis for discussion. The discussion below generally follows the licensee's agenda. The NRC staff interjected periodically for questions or clarifications. A summary of licensee and NRC staff comments N
follows.
3.2 0,erview and Historical Devel.opment of the' Safety Review Process s
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The President of GDUNC initially led a discusifon with an overview and historical perspective of the licensee's technical and safety
.(T&S) review process. He stated that, as a result of the TMI-2 accident..and during,the TMI-1 restart hearing process, GPUN.saw the need for and made a strong commitment to an expanded scope of safety review with the introduction of the important-to-safety (ITS)
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concept-(in distinction to the traditional safety-related concept).
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This was an initial attempt at a graded approach to safety review with the issuance and implementation of the revised technical specifications (TS) in 1982.
From 1982 to 1984, the relatively new process was monitored by the
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s licensee'r.nd they began to recognize the need for improvements.
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.s Apparently, tha ITS concept was not fully understood; but, more i
importantly, there was a need to more effectively use resources to
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enhance really reeded safety reviews.
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The President of GPUNC'went on to say that the graded approach to safety review was adequate and it proved to be effective in conjunc-tion with collegial reviews. However, there was a need for addi-tional screening of procedure changes as to whether or not the change was within the scope of 10 CFR 50.59. Thus, the. o ptep process (Step 1, Form 1; Step 2, Form 2; re: NRC Inspection, Report No. 50-289/86-17) was created.
Further, he stated ttiat the new safety review process was substantially thought out over a two year period, done right, and endorsed by the licensee's General Office Review Board (G0RB) and the licensee's Nuclear Safety and Compliance Committee (NSCC).',The GORB did, however, suggest improvements with emphasis on training and it concluded that the process meets TS.
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Before a more detailed discussion of specific issues, the President of GPUNC summarized by stating that the new safety review approach is being driven to enhance safety, not by human resources considerations.
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The discussiori then led into specific issues addressed in NRC Inspection Rbport (IR) No. 50-289/86-17 and the recently completed
'P'erformlnceAppraisalTeamandSystematicAssessmentofLicensee-Perform ance r corts.
3.3 Nu'elear[nstrumentCableModification TheIR86-17identifiedanapparentviolationofNRCrequirementsregard-ing' the failurd to propeHy evaluate a change to a cable-to-reactor building penStration connection rendering a channel of nuclear instrumen-s L
tation inoparable during a plant startup.
Licensee representatives reported that this problem did not result from any inadequacy of T&S reviewprocess.
It was related to a drawing control problem from the early ly80's/and the lfcensee will be addressing their corrective actions in theie response to the Notice of Violation.
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t The NRC staff acknowledged the licensee's comments for this specific item.
3.4 Special Temporary Procedures (STP's)
The subject inspection reports identified that some STP's were not clusifiedJTSwhentheydealtwithITSsystems. The licensee ack1cwledged past problems in this area. They pointed out that the new safety review process no longer distinguishes ITS versus NITS (not; US) and their corrective actions are embodied in the new
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safety review crocess.
s The NRC staff explored this issue considerably as noted below under the adequacy of the new safety review process.
3.5 Modification Control Corporate Procedures
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The subject inspection reports identified that the majority of the
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licensee's corporate-based modification control procedures (Technical Function Procedures) were declassified from ITS to "no safety review
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required." The licensee reported that they reviewed this area and have reconfirmed their original determination that only four of these procedures require safety review specified by Technical Specifications.
The remainder of the procedures receive reviews as specified in the QA plan. They reported that they believe their position is consistent with the Technical Specifications and Regulatory Guide (RG) 1.33.
The NRC staff stated that this area will be closely reviewed in a future inspection.
3.6 Adequacy of the New Technical and Safety ;eview Process
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The licensee stated that the new technical and safety (T&S) review process was based on Nuclear Safety Analysis Center (NSAC) Report i
No. 105, dated July 1986.
(The NSAC is operated for the electric utility industry by the Electric Power Research Institute.) Further, the licensee
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reported that they reviewed a sampling of procedure changes since the new T&S process was effective September 1,1986. Approximately 1200 changes were made at the Corporate, Oyster Creek, and TMI-I sites. Of that 1200, 93 were reviewed in detail to assure proper implementation of the new process. Only one of the 93 changes should have a Form 2 when only Form 1 was used. Although that review is continuing, the licensee tentatively concluded there is relatively good understanding of the new system and that it is properly being implemented.
Licensee representatives then summarized the process with substantial questioning by NRC staff.
Form 1 is essentially the initial screening criteria as to whether a detailed safety evaluation (described in 10 CFR 50.59) is needed.
Environmental considerations are also determined.
There is a broad question as to whether or not the change has an effect on
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plant safety. After substantial questions, the NRC staff concluded that l
changes to NITS system operating procedure would get the Form 1 review, I
which is a broader review than that required by TS. The NRC staff expressed concern, however, that no written justificction is provided to support the conclusions reached in the Form I screening process. The licensee acknowledged and stated that, prior to this management meeting, they decided that the T&S process would be revised to include a written justification for negative answers to the questions on Form 1.
Form 2 is essentially the traditional questions to ask on whether or not an unreviewed safety question existed.
This form would be completed if Form 1 determines that the change is within 10 CFR 50.59 scope. The licensee stated the Form 2 already requires written justification for answering the questions negatively. The licensee also pointed out that in answering Form l's questions, the licensee wanted their reviewers to go beyond the "' CFR 50.59 questions in terms of effect on plant safety.
The NRC staff still questioned how the questions of Form 1 could be answered without exercising the thought process intended by Form 2.
This area will be further reviewed during the resolution of related l
inspection findings for ITS changes. The staff acknowledged licensee
planned actions to revised Form 1 to explain negative answers to the
form % questions and the licensee application of Form 1 to NITS system (an i
expt..ded scope of review beyond TS requirements).
l The licensee and NRC staff discussed the definition of a substantive
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revision in the new T&S review process (Question 2 on Form 1) in relation to Temporary Changes (TC) permitted by TS 6.8.3.
The licensee representa-tive stated that a "no substantive" revision was narrower in scope than a TC. Also, they informed NRC staff that that question was not used in the TMI-1 site specific procedure. The NRC staff pointed out that nonsub-stantive procedure revisions do not get the rest of Form 1 to be completed and questioned the consistency of that process with TS. The TS require all changes to be reviewed with a determination as to whether or not an unreviewed safety question existed.
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The adequacy of the screening process for substantive versus nonsubstan-tive revisions to procedures at the corporate level remains open pending
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additional review by NRC staff to assure compliance with TS.
Licensee representatives added that sufficient guidance exists for reviewers to do a detailed T&S review. They acknowledged that the term " licensing basis documents" in the T&S control procedures needs to be better defined.
The licensee representatives indicated that the collegial review processes were working effectively, except that more use of that process could be used at Oyster Creek. The collegial review process will continue to monitor and/or confirm the results of the new T&S process.
3.7 Procedure Compliance Task Group (PCTG)
At the conclusion of the safety review discussion, licensee representa-tives summarized the results of the PCTG effort and reported on the status
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of implementing the group's recommendations. The results discussed were essentially those summarized in NRC Inspection Report No. 50-289/86-19.
The licensee acknowledged that the number of procedure nonadherences was too high; it has been a problem in the past; and they were hopeful that the corrective action, as a result of the PCTG effort, should reduce that number substantially. They stated that corrective actions should be essentially completed by September 1987.
Corrective actions include establishing a clear policy or procedure adherence that could be under-stood by all personnel and provide for monitoring by QA department to judge effectiveness of these measures.
The NRC staff had no specific comments on this issue, but they reiterated their anticipation that the procedure adherence problem will be resolved as a result of the PCTG effort.
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Meeting Summary /Conclutign The NRC staff preliminarily concluded that the new T&S review process met the intent of applicable TS (Section 6.8.1 through 6.8.3), but questions remain concerning the specific methodology used to implement TS and on the inconsistency of terminology used in the present T&S review with respect to TS.
Ideally, the TS should be revised to eliminate confusion with respect to the T&S review process.
Because of those residual questions noted above, it was decided that a Region I inspector would review specific examples of procedure chan5es at the Corporate Office to get a better understanding of the implementation of this new process. That review was conducted on February 18, 1987 (see paragraph 5 below).
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The NRC staff also summarized their understanding of commitments made by the licensee during the meeting.
The licensee's T&S review process will be revised to assure an
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explanation of negative answers to the questions on this initial screening process delineated by first form of licensee's two-step process.
The licensee will continue to evaluate the effectiveness of procedure
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changes using the new T&S review process.
More guidance was to be issued by the licensee, especially in the
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area of what constitutes a " licensing basis document."
From the discussion, the NRC staff noted that little formal guidance existed on how reviewers were to. determine an affect on plant safety; in particular, how to go beyond the 10 CFR 50.59 traditional questions on whether or not an unreviewed safety question existed.
The NRC staff concluded that the meeting was mutually beneficial for each party to understand respective positions on the items discussed.
5.
Followup Corporate Inspection As noted above, a Region I inspector reviewed a sampling of procedure changes at the Corporate Office in Parsippany, New Jersey. The purpose of this review was to get a better understanding of how the licensee imple-ments their new T&S review process and to confirm licensee's statements made at the Management Meeting of February 12, 1987. The inspector met with Messrs. R. Germann, P. Well, and Ms. K. Kowkabany. The inspector had the following observations.
TMI-I site administrative procedures consider all changes to ITS
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' system as substantive; therefore, the corporate screening question is not used at TMI-1.
It appears that the screening question remains applicable to Corporate and Oyster Creek procedures.
There were a number of Form 1 completions for changes to procedures
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dealing with NITS systems; e.g., Makeup Demineralizer Neutralizer Tank and Condensate Polisher Flow Range Instruments. This had the advantage that reviewers had to think about whether or not a TS or FSAR change was needed for a NITS procedure / facility change.
The inspector learned that a TMI-1 internal memorandum, dated
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January 26, 1987, from the Manager of Safety Review, TMI-1, to Plant Review Group Members was issued and the memorandum requires that for ITS system a "yes" is to be marked for an affect "on plant safety" (Question 3 on Form 1).
The site policy automatically requires the Form 2 10 CFR 50.59 evaluation for ITS procedure changes. This action alleviates
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NRC staff concern with respect to proper implementation of specific TS requirement in the area of T&S review for site activities.
It was noted that this action did not apply to the Corporate and Oyster Creek sites. There are questions on the implementation details and dissemination to all reviewers of this action, which will be pursued during NRC Inspection 50-289/87-06.
In general, Form 1 review causes individuals to think about whether
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or not the TS or FSAR needs revision independent of its safety classification.
A number of procedure change request forms were not properly
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completed with respect to providing a reason for the change.
If the reason for change is because of system modification, the modification number was to be given.
In some instances, the modification number was not given. This was discussed with the licensee.
The inspector concluded that the new T&S review process met the intent of TS and 10 CFR 50.59, but there is still a problem with how the safety evaluation documentation should reflect completion of these requirements.
The inspector reiterated a staff concern that the TS terminology and methodology should be consistent with the new T&S implementation program.
Licensee representatives agreed to continue to review this area to determine if a.TS revision is warranted.
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ATTACHMENT NRC INSPECTION REPORT NO. 50-289/87-04 I.
INTRODUCTION II.
SAFETY REVIEW PROCESS A.
Overview 1-8.
Historical Development C.
Issues Identified by NRC in PAT II, SALP II, IR 86-17 o
NRC Issue o
GPUN Analysis / Response III.
PROCEDURE COMPLIANCE TASK FORCE A.
Overview of Task Force Report B.
Status of the Task Force C.
Future Actions Related to Task Force Findings IV.
CONCLUSIONS
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