ML19329G101

Followup Safety Evaluation Interrogatories Directed to NRC, Re Mgt & Technical Capability,Operational QA Program & Tech Specs Per IE Bulletin 79-05A Ref.Certificate of Svc & Supporting Documentation Encl

ML19329G101
Person / Time
Site:	Three Mile Island
Issue date:	07/01/1980
From:	Widoff M THREE MILE ISLAND ALERT, WIDOFF, REAGER, SELKOWITZ & ADLER
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8007140003
Download: ML19329G101 (11)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

,DEFORE THE ATOMIC SAFETY AND LICENSING BOARD p A b

In the Matter of ) , USNRC ,o METROPOLITAN EDISON COMPANY

) 2 Docket No. 50-289 E' JUL 81980 > 5

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) (Restart)

EcedW Docketing & Smice W j (Three Mile Island Nuclear  % Smeh

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Station, Unit No.1) ) s a 0

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TMIA'S FOLLOW-UP INTERROGATORIES BASED ON THE SER TO NRC STAFF These follow-up interrogatories are promulgated pursuant to the Board's Order cf June 23, 1980, requiring discovery requests based upon new information in the SER be served by July 1,1980.

1. In the introductory paragraph of Order Item 6, the Staff concedes that "our evaluation . . . is incomplete" and that "an updated evaluation in a supple-ment" will be provided.

A. When will the completed SER be provided?

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2. The following interrogatories are based on the Management and Technical Capability section of Order Item 6.

A. When will the new " 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 i'?

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 mainte-nance personnel."

1. How many people have been added to maintenance and in what capacity? .

2. Will the Staff' evaluate the competence of the new personnel?

3. If so, what criteria will be used?

4. Has the NRC Staff evaluated past deficiencies in the quantity and quality of maintenance personnel?

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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 ex;iertise on the Three Mile Island Station and on TMI-1" (em;,nasis added) .

1. What data was used in reaching this conclusion?

2. Did the NRC Staff consider past maintenance practices of the Licensee?

a. Did it evaluate any work requests?

(1) If so, which ones?

(2) Did the NRC Staff consider the tremendous backlog of work. requests in identifying the deficiencies of Licensee's maintenance practices?

(a) How will the new changes improve this situation?

b. Will the NRC Staff recommend the use of periodic outages (independent of refueling cutages) to reduce the mainte-nance backlog?

(1) If not, what safeguards exist to p. event the backlog problem?

3. Did the NRC Staff evaluate the proposed maintenance budget cuts in determining Licensee's commitment to maintenance and repair? -

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4. -Did the NRC staff consider the past and/or future role of independent contractors in Licensee's maintenance plans?

a.- If s6, 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 recommendations;

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 cver plant operational activities .

Has the NRC Staff considered recommending revisions 1.

designed to improve the interface between operations and maintenance?

2 .' Particularly, has the NRC Staff considered revisions improv-ing the origination of work requests and the assignment of priorities by operations personnel?

J. Please explain why TMIA's copy ef page C6-4 ends with a com-pleted sentence and C6-5 begins in mid-sentence (Attachment " A" cintains TMIA's pages C6-4 and C6-5) .

1. Please provide the correct pager C6-4 ar.3 C6-5.

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3. The following interrogatories are based on the Operational Quality Assurance Program section of OrderItem 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?

h. 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 TMI-2 accident?

B. Will the audit of " selected maintenance, inservice, health physics and QA procedures" be completed before the restart hearing begins?

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4. The following interrogatories are based on 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 Staf' consider the amount of overtime worked by maintenance employees in determining the adequate number of maintenance personnel required?

If so, provide the documents evaluated.

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5. The NRC Staff mentions " Technical Specifications" in part 10 cf IE

- Bulletin 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 1 for inspection.

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• Respectfully submitted, WIDOFF, REAGER, SELKOWITZ & ADLER, P.C.

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/C ' M6rk P. WidoIf [Q N O. Box 1547 Harrisburg, PA 17105 (717) 763-1383 Dated: July 1,1980 e

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CERTIFICATE OF SERVICE I hereby certify that I caused a true and correct copy of the foregoing document, TMIA's Follow-Up Interrogatories Based On The SER to NRC Staff, to be placed in the United States mail, first-class, postage prepaid, addressed to the persons listed below:

Ivan W. Smith, Chairman Atomic Sa'etf & Licensing Bcard Panel U.S. Nuclear Regulatory Ccmmission o A.

,hington, DC 20555 fe. g DOCKETED g ter h. Jordan &

w est Outer Drive -

UsNRC s Oak Ridge, TN 37830 2 JUL 8M> 7 E' O!!!ce cf the Sut14 10 Dr. Linda W. Little Dod.eting & sel:e Eranch 5000 Hermitage Drive is //

Raleigh, ::C 27612 ~

l g, George F . Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street, ::.W.

Washington, DC 20006 Docketing and Service Section U.S. Nuclear Regulatory Commission Washingten, DC 20555

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Executive Legal Director U.S. Nuclear Regulatory Commission Washington, DC 20555 ,,

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// Mark P. Widoff p Dated: July 1,1980 y -- - . . -

• . e ATTACHMENT A t

As a result of the TMI-2 accident, we are developing new criteria with respect to the management and technical resources needed by utilities with operating power reactors to prevent and respond to accidents like the THI 2 accident. _Ve expect these criteria to be completed during 1980. V7willevaluateTMI-1acainstthesenewcriteria.and '

where appropriate will recuir" Met-Ed to correct any deficiencies prior to restart of TRI-1. In the meantime, the staff has been using the draft criteria in a subjective Mon to evaluate several utilities applying for operating licenses. As reported herein, we also have used, and are using, these draft criteria in part for our sub-jective evaluation of the Met-Ed/GPU management and technical resources for operation of THI-1.

The licensee has made extensive revisions to the management controls for plant opera-tional activities. These include the following activities:

(1) Shif t relief turnover check lists which will require identification of control room valve and switch positions for all SFAS and EFW systems ano state the recuired and actual valve and switch positions to fully indicate system status at time of transfer of responsibilities (see Order item 8).

(2) Periodir verification of all SFAS and EFW valve and switch positions for those valves and sutch positions that are not indicated in the control room.

(3) Independent verification of valve and breaker lineups for correct positions following maintenance, surveillance, or special operation on SFAS and EFW systems.

(4) System checklists will be completed by the control room watch, primary plant, secondary plant. and out-building auxiliary ope.ators during their shift. These system checklists will be reviewed and signed by the off going and'on coming auxiliary operators and centrol mom watch te assure knowledge of system status at shift turnover time.

(S) Revisions to the operational quality assurance program (see below).

(6) Revisions to the radiation protection program (see below).

These activites are expected to provide improved management information on and control over plant operational activities.

ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," and Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)," which endorses ANSI N18.7-1976, are currently under revision, and are expected to be available by mid-1980. This standard and guide will cover upgraded managerial controls of plant activities. The licensee's upgraded managerial controls will be evaluated against these new management controls.ac.d addi-tional changes will be requireo of THI-1 as appropriate.

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and action a willingness to remedy these ceficiencies. As described above, many actions taken by the licensee will improve their capabilities in these areas.

However._ because there still remain incomplete ...f ons by Met-Ed to reach their management improvement 9044 , and because we still are in tne process or ceveioping new evaluation criteria in these areas, we cannot conclude at tnis time snat Met Ed i~s 7 Y ompliance with the Order in the area of management . technical capacility, adecuacy of groups provicing safety res iew and coeratir,ial advice. and cacability of ~

the plant maintenance organization. ,

To date, Met-Ed has taken several steps toward improv'ing its site organization. It has revised that organization several times since the THI-2 accicent, including a major reorganization in November 1979 and a further revision in March 1980, as described above. We believe this November 1979 reorganization as modified in March 1980 will improve Met-Ed's canagement capability. To fully resolve the open issues discussed above, we will: require appropriate clarification c' the Restart Report in this area and submittal of additionu information on staf fing and on the prcposed new corporate organization; complete our review of that information; evaluat TMI-1 organization, management, technical resources, cualification of staff meroers, and managerial c ntrols against our newly develcped criteria; and report on these matters in a supplement to this evaluation.

SAFETY REVIEW AND CPECATICNAL ADVICE Met-Ed has established provisions for providing ope ational advice for THI-1. These of fsite provisions will be provided througn the TMI Generation Group's Tecnnical Functions and Nuclear Assurance organizations (see Figure 6-1). The Tecnnical Functions group will provide a centralized technical capability to support the plant staff in the areas of general meenanical, civil, electrical and instrument and controls support, and in the areas of fuel management, process computer, control and safety ana?/ sis and plant operational analysis. The Nuclear Assurance Group will provide technical capability in nuclear cuality assurance, radiation control, emergency planning coordination, technical trainirg, enemistry and metallurgy. In accordance with Co mission requirements, onsite coeratianal support will be provided by the assignment of a shift Technical Advisor to the site at all times the plant is in operation.

Safety review of operating activities will be provided by the offsite Generation Review Committee (GRC) and the onsite Plant Operations Review Committee (PORC). The GRC will be composed of at least five members and a full time chairman and will provide a review of activities such as safety evaluations, procedure changes, and conformance with regulations. The PORC is a plant-level group that will pru ide reviews of operational activities.

TRAINING OF OPERATING STAFF The licensee was directed in item 1(1) of the Order to augment the retraining of all Reactor Operators and Senior Reactor Operators. Additional requiroents for operator training are found in Parts 6 and 7 of Order Iten 1:a). Items 3, a, 5, 7, 8, 9 ano 10 C6-5

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