ML19261F015
| ML19261F015 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/03/1972 |
| From: | Van Niel C US ATOMIC ENERGY COMMISSION (AEC) |
| To: | Ross D US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 7910180604 | |
| Download: ML19261F015 (9) | |
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THRU V(fWR-2, Division of Reactor Licensing D. Ross
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p D. Thompson, Chief, OSB, DRL j
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1.EVIEW OF FINAL SAFETY ANALYLIS REFORT FOR THE THREE MILE ISTED NUCLEAR POWER PIMI - UNIT 1 (DOCKET NO. 50-289) t I have conducted a review of the FSAR of the above applicant in the areas of Conduct of Operations. Initial Tests and Operations, and i
the Administrative Controls section of the Technical Specifications.
Additional information will be required of the applicant in order to complete the review in these areas. Enclosed is a list of l
questions and statements which identify those specific areas which t
were found to be inadequate. It is reconsnended that the list be I
forwarded to the applicant for his consideration and resolution.
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C. R. Van Niel f
Operational Safety Branch i
Division of Reactor Licensing l
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Enclosure:
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Questions & Statements i'
cc:
D. J. Skovholt, DRL C. G. Iong, DRL t
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Jlli 2 1272 TilREE 11ILE ISIA::D 1 (DCCKET 50-289)
SECTION 12, CONDUCT OF CPERATIONS FSAR Section 12.1.1 1.
Provide information concerning the corporate technical support organization that will specifically support the operation of the nuclear plant.
Include a description of the duties, responsibilities, and authority of the " Engineer in Charge" and the assigned engineer-ing technical staff.
Provide, by way of resunds, information con-cerning the qualifications, educational backgrounds, and experience of the corporate technical support staff (Ref erence ANSI-Nld.1).
12.1.2 2.
Provide a description of the function, responsibility, and authority of the Control and Instrument Fo r ena n.
This is considered a key supervicory position.
(See ANSI-N18.1.)
12.1.2 3.
Describe the duties and the authority delegated to the Station Enginecr, Nuclear Engineer, Chemical Supervisor.
12.1.2 4.
Provide resumds of all key supervisory personnel to include qualifi-cations, educational backgrounds and experience, and specific nuclear training.
These include the Station Superintendent, Supervisor of Operations, Supervisor of >bintenance, Station Engineer, Control and Instrument Foreman, the five Shif t Foremen, Nuclear Engineer,
Radiation Protection Supervisor, and Chemical Supervisor.
12.1.2 5.
Provide a description of the qualifications required by individuals selected to fill each of the positions listed in 12.1.2.
Add the qualifications for the position of Control and Instrument Fo r ema n.
(See ANSI-SIS.1.)
12.1.2 6.
Describe the specific succession of responsibility of supervisory personnel for overall operation of the facility in the event of absences or emergencies.
12.1.2 7.
Explain the functions and responsibilities of unlicensed operators and technielans.
12.2.1.2 8.
Provide a detailed description of the nuclear training program for the plant non-supervisory personnel, including both formal and on-the-job training.
Give the duration of each aspect of the program (ANSI-N18.1).
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12.2 9.
Provide a description of the general employee training given to all personnel regularly employed at the nuclear plant.
12.2 10.
Designate the individual responsible for the adm.nistration of 4
the training program. Who evaluates the cifectiveness of the training program?
12.2 11.
What provisions have been made for replacement and retraining?
Describe in detail.
Is the use of a plant simulator anticipated?
12.2.3 12.
What training is provided for those offsite organizations that may be called upon to assist plant staf f during an emergency?
12.2.3 13.
Provide a ccomituent that the agreements with of f site organizations for emergency assistance are in writing.
12.3.1 14.
Provide a corraitment that not only will detailed tritten procedures be prepared but that they will be used in the operation of the plant. Provide a list of the titics of all procedures.
12.3 15.
Describe the system for the revision (including icview and approval) of plant operating, maintenance, testing, and caergency procedures.
12.4 16.
Specify the retention period of all records listed in subsection 12.4 and subsection 15.6.5.
12.4 17.
Describe the provisions made for maintaining records of qualifica-tions, experience, training, and retraining of each member of the plant staff.
Fig.
12.1 18.
Designate on Figure 12.1 the key supervisory personnel for which 15.6.1.F minimum qualifications are specified in the Technical Specifications.
12.2.3 19.
Has the emergency planning program considered caergencies other than those listed, e.g.,
natural disasters, transportation accidents, and sabotage.
12.2.3 20.
Uho will evaluate onsite and off site radiation levels following an accident? What predetermined action levels have been developed for implementation of protective measures? Uhat recommendations will be made to local authoritics for evacuation, take cover, or other protective measures for various action levels?
12.3.5 21.
What is the membership of the Emergency Planning Group?
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APPENDIX 12A - RADIATION E!!ERCEECY PLAN FSAR APPENDlX 12A SECTION 2.6 1.
Where are the Emergency Monitoring hi's located?
3.2.1 2.
The job assignments of the Station Superintendent and the Station Engineer appear to conflict with the Emergency Operating Organiza-tion in Figure 12A.-3.
3.2 and 3.
Who are the designated alternates during a radiation emergency, App B for the Station Superintendent, the Supervisor of Operations and the Station Engineer?
4.2.3 and 4.
Explain the rationale of not declaring a Genera'l Emergency on 6.3.2 the occurrence of a major accident which could potentially result in the release of radioactive material to the environment.
Provide the quantitative basis for requesting offsite assistance af ter the Radiation Protection Monitoring Team has determined that a high radiation level exists at the site boundary.
5.7 5.
How do the holders of the Radiation Emergency Plan know that they have the latest revision cf the plan? For example, Section 5.7 and Appendix C are not current. How is the Radiation Emergency Plan kept current?
7.2 6.
Are the arrangements for emergency assistance with the Hershey Medical Center, and other offsite organizations, in writing?
8.0 7.
What is meant by " periodically" with regard to the review and revision of the Radiation Emergency Plan? What specific pro-visions have been made?
10.0 8.
On what frequency will training, retraining, and drills of the emergency plan be held? What provisions have been made for training offsite personnel from organizations who might provide emergency assistance?
11.0 9.
The recovery and reentry section is inadequate.
Expand this area to include such matters an:
exposure guides for rescue personnel, provisions for the rescue of personnel, the determination of the accessibility of plant areas follouing an accident, the availability of current operating records, the storage of building plans, pro-cedures, and other essential information in a location readily 1486 073
_2-accessible in an emergency, intervicuing evacuated employees to obtain infornation about the energency, and the designation of a technical group to detcraine reentry advisability.
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SECTIO" 13 - INITIAL TESTS A?;D OPERATIONS FSAR SECTION 13.2 1.
Describe the administrative procedures to be followed to incorporate any system or procedure nodification if the results of a test are contrary to expected results or if the test procedure proves to be inadequate.
13.2.1.2 z.
Provide a list of the membership of the Test Working Group, includ-ing their field of expertise, education, and technical training.
13.2.1.3 3.
Describe what actions will be taken by the Plant Operations Review Committee if the execution or results of any test are deemed unsatisfactory.
13.2.1.2 4.
At what period in the initial startup of the plant will the Test Working Group cease to function?
13.2.2 5.
Explain the tern " general direction" with regard to the execution of functional and operational tests?
13.2.2 6.
Explain the interrelationships of the Test Working Group and the Plant Operations Review Conmittee with regard to the testing program.
13.4.1 7.
Explain the responsibility and authority of the GPU Quality Assurance personnel for initial fuel loading.
(It appears that Section 1.6.2 is written exclusively for the design and construc-tion phase.)
13.4.1 8.
Provide a schedule of those procedures to be used during initial startup and power ascension f acluding the plant conditions (uith power levels) at which the tests will be performed.
Refer to the Guide for the Planning of Initial Startup Programs, dated 12/7/70.
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SUBSECTIO" 15.6 - ADMIMISTRATIVE CONTROLS FSAR SECTION 15.1.2 1.
Provide justification for excluding from the definition of Abnormal Occurrences the following statements:
" Observed inade-quacies in the implementation of administrative or procedural controls such that the incdequacy causes or threatens to cause the existence or development of an unsafe condition in connection with the operation of the plant," and " Conditions arising frca natural or of f site nanmade events that affect or threaten to affect the safe operation of the plant."
Subsection 15.6.3 uses the ANS 3.2 definition.
15.1.2 2.
Why is abnormal occurrence definition "c" linited 'to a radioactive release from the site, excluding releases from any plant system designed to act as a boundary? Reference proposed standard ANS 3.2, draft 6, of 9/8/71.
15.6.1 3.
Specify the minimum nunber of licensed and non-licensed operators present during the follouing plant conditions:
fuel loading and refueling, cold shutdown, and hot shutdown or operation.
15.6.1 4.
Justify the provision for the recuirement of only one licensed control room operator as specified as a footnote on page 15-95.
This disagrees with Figure 12.1 which specifies 10 licensed reactor control room operators for the 5 shifts.
15.6.1 5.
What provision is made for health physics coverage on shift?
15.6.1 6.
What is neant by " Normal" in Specification E of subsection 15.6.l?
15.6.1 7.
For Specification F of subsection 15.6.1, list the positions by title that are referred to (See ANSI-N18.1).
15.6.1 8.
Provide a copy of the written charter for both the Plant Operations Revieu Committee and the General Of fice Review Board.
Include, as a minimum, the provisions listed in Section 4 of ANS 3.2.
15.6.1 9.
Justify the inclusion of two members of the Cencral Office Review Board on the Plant Operations Review Committee.
Their participa-tion in Committee meetings vould make their effectiveness on the Board for independent audit questionable.
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15.6.1 10.
Provide the basis for establinhing less than a majority of the Plant Operations Review Committee as a quorun.
11[ For the General Office Revicu Board, identify by title and list 15.6.1 the technical specialty and experience of each member.
Designate the Chairman and Vice Chairman.
15.6.1 12.
Explain the omission of the following responsibilitics of the Board:
revieu of tests and experiments and their results, which a.
may constitute an unrevicued safety hazard.
b.
review of significant operating abnormalities or deviations from normal and expected performance of plant equipment.
Fig.
15.6.1-1 13.
Does the General Public Utilities Nuclear Pouer Activities Group provide the corporate technical support for the plant? If so, provide a list of the assigned engineering technical staf f, their qualifications, educational background, and experience, and their responsibility and authority over plant operations.
If outside consultants are used for technical support for plant operations, specify areas of responsibility and functional working arrangements.
15.6.2 14.
The listing of the detailed procedures in subsection 15.6.2, Specification A is not complete.
For example, procedures for surveillance and testing, plant emergencies, and industrial security are not included.
Provide a conplete list of the types of procedures to be used for plant operacions.
15.6.2 15.
Specify the frequency of review of operating procedures and emergency procedures by operating personnel.
15.6.2 16.
What is the plant's policy for adherence to written procedures which are not safety related? Will " temporary" minor changes in procedures, approved by the Shift Foreman, be revicued and approved by the Station Superintendent or the Plant Operations Review Committec?
15.6.3 17.
Is the General Office Review Board specifically charged with the review and approval (with appropriate recommendations) of reports of abnormal occurrences and of exceeding a safety limit (sub-sections 15.6.3 and 15.6.4)?
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n 15.6.5 18.
The specification under subsection 15.6.5 does not include such items as fuel exposure, shutdouns, fuel inventories and transf ers, minutes of meetings of review and audit groeps, and reactor coolant system inservice inspections.
Provide a complete listing of the station logs and records to be retained, with a retention period given for each.
15.6.6 19.
Provide justification for the proposed exception to the 10 CFR 20 regulation regarding the control of access to high radiation areas.
15.6.7 20.
Will the written reports submitted to the AEC per specification B of subsection 15.6.7 include:
(a) an outline of the measures taken to assure that the cause of the incida.it has been determined,
and (b) a discussion of the incident as it relates to similar incidents?
15.6.7 21.
Subsection 15.6.7 does not include the provision 'for a Startup Report and a First Year Operations Report.
The subsection does not address the following events that sho'ild be reported within 30 days:
inadequacy in the inplementation of administrative or procedural controls, conditions involving a pessible single fai?are, occurrences or conditions involving an offsite threat to the safety of operation of the facility, and any substantial variance from performance specifications.
Specify what "o t her information" will be included in the operations sunnary of the six month reports, e.g., procedure changes and results of tests and inspections.
(See Saf ety Guide 16.)
Include under Shutdown, information as to plant status during outage, and corrective action taken to prevent repetition, if appropriate.
Expand the Maintenance and Facility Changes paragraphs using Saf ety Guide 16 as guidance.
Include a designation of the destination of waste shipments.
Elaborate on what is meant by "A summary of results,"
under Environmental Monitoring.
Does this include the highest,
lowest, and average concentrations or levels of radiation for the sampling point, and the number of locations at which levels are found to be significantly above local background?
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