ML19321A561
| ML19321A561 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/21/1980 |
| From: | Swanson D NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | THREE MILE ISLAND ALERT |
| Shared Package | |
| ML19321A555 | List: |
| References | |
| NUDOCS 8007230617 | |
| Download: ML19321A561 (20) | |
Text
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STAFF 7/21/80 G
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDISON COMPANY, ET AL.
Docket No. 50-289 (Three Mile Island Nuclear Station, Unit 1)
NRC STAFF RESPONSE TO TMIA FOLLOW-UP INTERROGATORIES Pursuant to 10 C.F.R. 5 2.720 and 10 C.F.R. 5 2.744, the NRC Staff has responded to "TMIA's Follow-Up Interrogatories Based on the SER to NRC Staff dated July 1,1980." Each interrogatory is restated and a response provided. Where appropriate, the NRC Staff has invoked that portion of the Commission's Order of August 9,1979 (Slip Op. at 11) which allows as an adequate response to a discovery request a statement that infomation is available in the Local Public Document Rooms and guidance as to where the infomation can be found. Affidavits identifying the individuals who prepared the responses and verifying them are not available and will be sent at a later date.
Respectfully submitted, h
I w
Daniel T. Swanson Counsel for NRC Staff i
Dated at Bethesda, Maryland I
this 21st day of July, 1980 80072304/7 '
TMIA FOLLOW-UP INTERR0GATORIES TO STAFF Interrogatory 1 In the introductory paragraph'of Order Item 6, the Staff concedes that "our evaluation... is incomplete" and that "an updated evaluation in a supplement" will be provided.
A.
When will the completed SER be provided?
Response
A supplement to the SER including an updated evaluation of the licensee's management capability is expected to be available in late September 1980.
I A
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Interrogatory 2 The following interrogatorCs are based on the Management and Technical Capability section of Order Item 6.
A.
When will the.a:w " support organization" be staffed?
B.
When will the NRC Staff evaluate the " support organization" staff?
C.
Define " properly staffed" as used on page C6-3.
D.
What criteria will be used in evaluating the " staff"?
E.
Who will be evaluated?
F.
Give each and every fact relied upon in reaching the conclusion that "when properly staffed, such an organization should be able to assure plant operation without endangering the health and safety of the public."
G.
The Staff notes a "significant increase in the number of maintenance personnel."
1.
How many people have been added to maintenance and in what capacity?
2.
Will the Staff evaluate the compstence of the new personnel?
3.
Ifso,whatcriteriawillbeused[
4.
Has the NRC Staff ev;.uated past deficiencies in the quantity and quality of maintenanc? personnel?
a.
If so, what information was evaluated?
b.
Provide the results of this evaluation.
H.
The Staff notes that "(t)hese changes are expected to provide improved management capability and control and improved technical expertise on the Three Mile Island Station and on THI-1" (emphasas added).
1.
What data was used in reaching this conclusion?
2.
Did the NRC Staff consider past mainterance practices of the Licensee?
a.
Did it evaluate any work requests?
(1)Ifso,whichones?
(2) Did the NRC Staff consider the tremendous backlog of work requests in identifying the deficiencies of Licensee's maintenance practices?
s'
. (a) How will the new changes improve this situation?
b.
Will the NRC I,taff recommend the use of periodic outages (independent of refueling outages) to reduce the mainten-ance backlog?
(1)
If not, what safeguards exist to prevent the backlog problem?
3.
Did the NRC Staff evaluate the proposed maintenance budget cuts in determining Licensee's comitment to maintenance and repair?
4.
Did the NRC Staff consider the past and/or future role of i
independent contractors in Licensee's maintenance plans?
i a.
If so, what information was evaluated?
5.
Define "are expected" as used in the above quote.
6.
What checks, if any, will be required to:
a.
assure compliance with the recomendations; b.
assure the new organization does what it is " expected" to do?
I.
The NRC Staff notes various revisions designed to improve " management information on and control over plant operational activities."
1.
Has the NRC Staff considered recommending revisions designed to improve the interface between operations and maintenance?
2.
Particularly, has the NRC Staff considered revisions improving
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the orgination of work requests and the assignement of priorities by operations personnel?
J.
Please explain why TMIA's copy of page C6-4 ends with a completed sentence and C6-5 begins in mid-sentence (Attachment "A" contains TMIA's pages C6-4 and C6-5).
1.
Please provide the correct pages C6-4 and C6-5.
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. Response A.
Metropolitan Edison is planning to submit additional information to the NRC on its support organization in a submittal to the NRC during the week of July 21, 1980. The licensee's plan for staffing this organization is expected to be included in this submittal.
B.
The NRC will evaluate the additional infonnation Met-Ed submits on its support organization.
C.
" Properly staffed," as used on page C6-3 means that all the allocated positions in the organization are filled by properly qualified people.
D.
The licensee's staff will be evaluated against the draft " Criteria for Utility Management and Technical Competence" (Staff; June 12,1980)and other " indicators" for judging organization and manegement.
E.
Individuals, organizational s9bunits, and the organization as a whole will be evaluated.
F.
As stated in D. above, the organization as described 2n the;"TMI Restart Report" will be evaluated against the draft "Criterie for Utility Management and Technical Competence" and other " indicators" for judging organization and manag' ant.
G. (1) The licensee's maintenance staff has been increased by the addition of approximately 50 persons. The NRC does not have the infonnation r.acessary to accurately determine in What capacity these persons were hired, r,ince it appears that several joo numbers and job titles were changed as e result the licensee's new organization. The sufficiency of the maintenance staff increase is being and will be monitored by the NRC's Office of Inspection and Enforcement (01&E) during the conduct of routine inspections by observing 4
. the-licensee's ability to cope with maintenance activities in a nore timely and organized manner.
(2) Yes. This will be accomplished during routine inspections conducted by the Ol&E. This evaluation will be completed prior to the issuance of the last SER supplement dealing with the management capability issue. How-ever, 01&E will continue to inspect on this matter after the issuance of the SER and its supplements.
(3) The criteria which will be used to evaluate the competence of new maintenance personnel will be ANSI N45.2.6 and ANSI 18.1.
(4) No. However, the Ol&E has performed and continues to perform routine inspections in the area of safety related maintenance which include an evaluation of the licensee's ability to perform maintenance activities.
H.
(1) The infonnation used is the reorganized plant staff and support organization as described in the TMI-l Startup Report.
The support organization provides a separate organization dedicated to the support of the TMI station with separate Directors or " Managers" for each major function and their attendant cechnical staffs. The establishment of this separate plant staff for Unit 1 under a VP level position provides greater management attention to the plant.
In addition, the technical capability of this plant staff is for Unit 1 support only. These changes are consistent with the NRC draft
" Criteria for Utility Management and Technical Competence."
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. (2) The OI&E is conducting and will continue to conduct routine inspections of the licensee's activities in the area of safety related maintenance. These inspections include the licensee's current maintenance practices, priority work request system, audit of celected work requests and their disposition, and surveillance of selected work activities.
a.
No. The routine OI&E inspection procedures in the area of maintenance do include an audit of selected safety related work requests and follow-up of work activities in progress.
Y (1) OI&E insp:cticn reports fcr TMI-1 and TMI-2 which p;rtain to maintenance are listed below.
Some of them involve audits of work requests, which are referenced in the reports. All of the reports are available for inspection at the local public docu-ment rpoms for the facility.
TMI-1 TMI-2 50-289/76-01 50-320/78-10 50-289/76-03 50-320/78-18 50-289/76-09 50-289/76-10 50-289/76-12 50-289/76-15 50-289/76-19 50-289/76-24 50-289/77-05 50-289/77-11 50-289/77-26 50-289-77-29 50-289/78-05 50-289/78-09 50-289/78-14 (2) No. Current inspections being conducted by the OI&E in the area of safety related maintenance activities include the licensee's progress in reducing the backlog of work requests. Routine inspections of this type will be continued throughout the life of the plant.
(a)
It is expected that the increase in the licensee's maintenance staff in conjunction with organizational changes and management commitments will enhance the licensee's ability to cope with maintenance activities in a more timely and organized manner.
. b.
No.
(1) Routine inspections, conducted by the OI&E, in the area of safety related maintenance will monitor the licensee's ability to maintain an appropriate maintenance schedule.
(3) The interrogatory is not clear as to which proposed maintenance budget cuts are being addressed.
(4) No.
It is recognized by the Staff and accepted that independent contractors (service organizations) are used by licensees in times of peak work loads, e.g., refueling and maintenance outagest and at other times, at the discretion of licensee management. This practice is routine not only in the nuclear industry but many other industries as well. However, when such service organizations are used in nuclear power plants, their personnel must be appropriately qualified in the discipline and to the level of work assigned.
(5) The real measure of how this new organization functions cannot be detennined until the plant is in operation. Therefore, we can only refer to their expected capability until the time that actually demonstrates capability (or incapability).
In the meantime, OI&E will continue to monitor TMI-l present activities.
J (6) a.
The interrogatory does not specify which reconinendations are being addressed. The referenced section of the SER does not mention any " recommendations."
s
. b.
Routine inspections conducted by the OI&E in accordance with OI&E inspection procedures will monitor that the new organization will do what it is expected to do to comply with NRC regulatory requirements, including license conditions and technical specifications.
I.(1)and(2)
The new organizational arrangement of the Supervisor of Operations and the Superintendent of Maintenance reporting to the Manager of Unit 1, who has no other responsibility than the operation and maintenance of the unit, should improve the interface between operations and mainten-ance. We are not recommending other revisions in this area.
J.
Pages C6-4 and C6-5 in TMIA's copy of the SER are identical to all other copies of the SER.
An editorial error caused the following words to be omitted from the top of page C6-5 immediately preceeding the first line on that page:
i "In summary, Met Ed has demonstrated an awareness of previous shortcomi.ngs in management capability and controls and technical capability, and has indicated by statement..."
This omission will be corrected in an Errata Page to be issued or in the next supplement to the SER.
f
Interrogatory 3 The following interrogatories are based on the Operational Quality Assurance Program section of Order Item 6.
A.
The NRC Staff notes that "the QA Staff has been increased."
1.
How much of this increase has been devoted to "on hands" personnel?
2.
Were any past QA and QC practices evaluated in considering what would be a sufficient increase in personnel?
a.
If so, which ones?
b.
Did the NRC Staff evaluate any work requests or QC surveillance reports in determining QA deficiencies before the accident?
(1) Provide a copy of all data considered.
(2)
If the above was not considered, what criteria were used in assessing pre-TMI-2 accident QA deficiencies?
3.
What is NRC Staff's assessment of the condition of QA before the THI-2 accident?
B.
Will the audit of " selected maintenance, inservice, health physics and QA procedures" be completed before the restart hearing begins?
Response
Within NRC, both the NRR and IE offices play an important role in assuring that (1) there is an adequate and correct QA program commitment (responsibility of NRR) and (2) the utility complies and implements these comitments properly and correctly (responsibility of IE).
Inherent in the IE review process is i
an assessment of an adequate staff size to properly carry out their commitments.
A.
(1) "On hands" personnel is interpreted to mean inspection personnel involved in inspecting and verifying activities associated with I
hardware as opposed to inspecting and verifying paperwork.
i y-a
e.
The TMI QA organization is directly responsible for the inspection and verification of activities associated with hardware including the inspection and verification of paperwork. This overall effort has been improved and made more effective by making QA responsible for determining what and when items are to be inspected during the early stages of design, procurement, specification, and procedure planning.
Associated with this action is the responsibility of QA to assure he has the necessary qualified personnel to properly carry out the identified inspection operations.
To preclude undue influence and pressure from the plant cost and schedule in this decision process, the QA Manager reports offsitt to a vice president where proper attention to adequate inspection staffing can be given.
l In the review for the SER, emphasis was placed on QA direct involve-i ment in the early stages of planning to determine inspection staff size rather than on getting a commitment to a specific inspection staff size.
It should be noted however that QA " hands on" inspection has been increased through their direct responsibilities for inservice inspection activities governed by ASME Section XII, " Inservice Inspection."
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1 1
- 4..
I&E has detennined that the licensee's on-site QA staff, devoted to "on hands" (sic) personnel, has been increased by the addition of 8 QA/QC persons.
In addition, currently there are 16 contractor QA/QC personnel to supplement the on-site QA staff in the perfor-mance of " hands on" duties. The number of contractor personnel will fluctuate with the work load and particular discipline required to accomplish the work. Also, the licensee's on-site QA staff currently involved in " hands on" inspection has been relieved of some duties allowing more time for these inspections.
These former duties have been transferred to other QA personnel on site.
(2) Past TMI QA/QC practices were evaluated to identify strengthes and weaknesses.
The major weakness in the TMI QA program was its limited scope and coverage and not the QA plant staff size. The NRC review, therefore, emphasized the need for (a) getting the necessary QA program commitments in the docket (b) increasing the scope and coverage of the QA program (c) gr. ting QA directly involved in the early stages of engineering and procedural planning to determine when and where inspections should be performed and (d) the QA lianager to report offsite to a vice president level independent of operating plant staff to assure sufficient independence from plant cost and schedules such that proper attention and considerations can be given to detennining inspection staff size.
In addition, sufficiency of the increase in the QA staff since the
m
. time of the accident is being and will continue to be monitored by I&E during routine inspections being conducted at TMI-1.
(a) Past QA and QC practices were not evaluated by NRR to deter-mine what would be a sufficient increase in QA personnel.
However I&E is conducting an ongoing evaluation in this area.
(b) NRR did not evaluate any work requests or QC surveillance reports in determining QA deficiencies before the accident.
However, routine inspections by the OI&E were conducted during which work requests and QC surveillance (and inspection) reports were audited.
(1) Refer to the following IE Inspection Reports which are available in the local public document rooms for the facility.
- 289/75-14
- 320/76-05
- 389/76-25
- 320/77-03
- 289/77-05; 320/77-09
- 320/77-26
- 320/78-10
- 289/78-09; 320/78-18 (2) NRR reviewed the TMI QA program used prior to the accident and findings from the President's Conmission Report and from NRC I&E inspection reports.
I&E inspection procedures were used during the conduct of routine inspections by I&E.
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(3) The NRC assessment of the docketed QA program prior to the TMI-2 accident was that it was acceptable and met the NRC criteria at that time. Since the accident, however, we find that the QA program was limited with respect to scope and coverage.
B.
Audits of " selected maintenance, inservice, health physics and QA procedures" are an inspection activity conducted by the OI&E. This inspection activity is ongoing and continues throughout the life of the plant.
It is not expected that the licensee will complete the preparation and implementation of all of these types of procedures prior to the beginning of the restart hearing; therefore, DISE can not determine the extent of their f r,itial audit of these procedures, at this time.
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Interrogatory 4 The following interrogatories are basedon the Plant Maintenance section of Order Item 6.
A.
Did the NRC Staff evaluate the priority system defined in AP 1407 for deficiencies?
1.
If so, provide the documents evaluated.
B.
Did the NRC Staff consider the backlog of work requests in evaluating Licensee's maintenance practices?
1.
If so, provide the documents evaluated.
C.
Did the NRC Staff consider the amount of overtime worked by maintenance employees in determining the adequate number of maintenance personnel required?
1.
If so, provide the documents evaluated.
Response
A.
No. Evaluation of the plant maintenance priority system has not been evaluated to date.
This evaluation will be conducted during routine inspections conducted by the OI&E in accordance with OI&E inspection procedures.
B.
No. The OISE is currently conducting and will continue to conduct inspections of the licensee's activities in the area of safety related maintenance in order to evaluate the licensee's performance relative to regulatory requirements.
C.
No. The Office of Nuclear Reactor Regulation and 0I&E will evaluate, in accordance with NRC criteria, the licensee's established policy in
~ this area to determine its acceptability. Upon acceptance, routine inspections, conducted by the 01&E, will determine the licensee's implementation Sf this policy.
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5.
The NRC Staff mentions " Technical Specifications" in part 10 of IE Bullstin 79-05A.
A.
Were the " Technical Specifications" evaluated by the NRC Staff for deficiencies in their appraisal of the amount of time a component can be nonfunctioning?
1.
If so, provide all documents evaluated and all results gained from the evaluation.
2.
Provide all " Technical Specifications" pertaining to TMI-Unit I for inspection.
Response
Bulletin 79-05A, Item 10 deals with procedures to assure operability of safety-related systems during maintenance and testss As noted in the SER on Page C2-8, we have concluded that the licensee is in compliance with this part of the Order.
The reference to Technical Specifications is a means of identifying the safety-related equipment to which this order item applies. No review of "the amount of time a component can be nonfunctioning" was rcquired or made under this Order item.
Such matters were considered in detail during the preparation of the Technical Specifications prior to licensing and where appropriate in subsequent revisions.
TMI-1 Technical Specifications are available for inspection and copying in the local public document rooms in Harrisburg and York, Pennsylvania and in the Public Document Room in Washington, D.C..
Draft Technical Specifications submitted by the licensee in response to various items of the Order may be found in Section 11 of the SER.
~
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S UNITED STATES 10F AMERICA HUCLEAR REGULATORY COMMISSION 8
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
.In the Matter of
)
METROPOLITAN EDISON COMPANY, Docket No. 50-289 ET AL.
(Three Mile Islaad,- Unit 1)
CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF RESPONSE TO SHOLLY INTERROGATORIES ON THE SER and NRC STAFF RESPONSE TO TMIA FOLLOW-0N INTERROGATORIES, dated July 21, 1980, in the above-captioned proceeding, have been served on the following, by deposit in the United States mail, first class, or as indicated by an asterisk, through deposit in the' Nuclear Regulatory Commission's internal mail system, this 21st day of July,1980:
- Ivan W. Smith, Esq.
Mr. Steven C. Stolly Atomic Safety & Licensing Board Panel 304., South Market Street U.S. Nuclear Regulatory Commission Mechanicsburg, Pennsylvania 17055 Washington, D.
C.
20555 Mr. Thomas Gerusky Dr. Walter H. Jordan Bureau of Radiation Protection 881 W. Outer Drive Dept. of Environmental Resources Oak Ridge, Tennessee 37830 P.O. Box 2063 Harrisburg, Pennsylvania 17120 Dr. Linda W. Little 5000 Hermitage Drive Mr. Marvin I. Lewis Raleigh, North Carolina 27612 6504 Bradford Terrace Philadelphia, Pennsylvania 19149 George F. Trowbridge, Esq.
Shaw, Pittman, Potts & Trowbridge Metropolitan Edison Company 1800 M Street, N.W.
Attn: J.G. Herbein, Vice President Washington, D. C.
20006 P.O. Box 542 Reading, Pennsylvania 19603 Karin W. Carter, Esq.
505 ' Executive House Ms. Jane Lee P.O. Box 2357 R.D. 3; Box 3521 Harrisburg, Pennsylvania 17120 Etters, Pennsylvania 17319 Honorable Mark Cohen Walter W. Cohen, Consumer Advocate 512 0-3 Main Capital Building Department of Justice Harrisburg, Pennsylvania 17120 Strawberry Square,14th Floor Harrisburg, Pennsylvania 17127
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Allen R.-Carter, Chairman John Levin, Esq.
Joint Legislative Committee on Energy Pennsylvania Public Utilities Comm.
Post Office Box 142-Box 3265 Suite 513 Harrisburg, Pennsylvania 17120 Senate Gressette Building Columbia, South Carolina 292n2 Jordan D. Cunningham, Esq.
Fox, Farr and Cunningham Robert Q. Pollard 2320 North 2nd Street 609 Montpelier Street Harrisburg, Pennsylvania 17110 Baltimore, Maryland 2121'8 Theodore A. Adler, Esq.
Chauncey Kepford WID0FF REAGER SELK0WITZ & ADLER Judith H. Johnsrud Post Office Box 1547 Environmental Coalition on Nuclear Power Harrisburg, Pennsylvania 17105 433 Orlando Avenue State College, Pennsylvania 16801 Ms. Ellyn R. Weiss Harmon & Weiss Ms. Frieda Berryhill, Chairman 1725 I Street, N.W.
Coalition for Nuclear Power Plant Suite 506 Postponement Washington, D.C.
20006 2610 Grendon Drive Wilmington, Delaware 19808 Ms. Marjorie M. Aamodt R.D. #5 Holly S. Keck Coatesville, Pennsylvania 19320 Anti-Nuclear Group Representing York 245 W. Philadelphia Street York, Pennsylvania 17404
- Atomic Safety and Licensing Appeal Board
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U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Counsel for NRC Staff
- Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Secretary U.S. Nuclear Regulatory Commission ATTN: Chief, Docketing & Service Br.
Washington, D.C.
20555 i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD _
In the Matter of METROPOLITAN EDISON COMPANY, Docket No. 50-289 ET AL.
(Three Mile Isltnd, Unit 1)
CERTIFICATE OF SERVICE I hereby certify that a copy of NRC STAFF RESPONSE TO SH0LLY "4 TERR 0GATRIES ON THE SER was hand-delivered to Steven C. Sholly and that a copy of NRC STAFF RESPONSE TO TMIA FOLLOW-0N INTERR0GATORIES was hand-delivered to Counsel for TMIA this 21st day of July, 1980.
CL Lucinda low Swartz Counsel for NRC Staff t
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