ML19338F201
| ML19338F201 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/02/1980 |
| From: | Boger B Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19338F186 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8010070628 | |
| Download: ML19338F201 (14) | |
Text
m UNITED STATES OF A' ERICA NUCLEAR REGUIATORY COf4ISSIQ:
BEFORE THE A10iIC SAFETf #;D L! CENSING BOARD
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In the Matter of
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METROPOL! TAN EDISOi C0tfPANY,
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Docket No. 50-289 et. al.
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(Three Mile Island tbelear
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Generating Station Unit 1)
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NRC STAFF TESTIMONY OF BRUCE A. B0GER REGARDI!U BYPASS AND I'N6PERABLE STATUS INDICATIO:
(UCS Contention 9) l Q.
1.
Please state your name and position with the NRC.
A.
My name is Bruce A. Boger. I am a Reactor Engineer assigned to the Operator Licensing Branch, Office of Nuclear Reactor Regulation.
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Q.
2.
Have your prepared a statement of professional qualifications?
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A.
Yes. A copy of this scatemnt is attached to this testimony, i
Q.
3.
Please state the nature of the responsibilities that you have had with respect to the Three Mile Island Nuclear Stations.
T A.
A' list of my activities is attached to this testinony.
Q.
4.
What is the purpose of your testinony?
802007o f &
A.
'Ihe purpose of my testinony is to respond, in i. art, to UCS Contention 9.
Specifically, my testinony supplenents that of !!r. Donald Sullivan, tac.
Q.
5.
Will the staff backfit Regulatory Guide 1.47 at M-l?
A.
'Ihe backfitting of Regulatory Guide 1.47 is the subject of Sections I.D.3.a and I.D.3.b of the tac Task Action Plan, lEHEG-0660.
In sunrnry, the staff is presently reassessing the untter of back-fitting Regulatory Guide 1.47 at operating plants. The Office of fluclear Reactor Regulation will study the need for all licensees and applicants not presently cocmitted to the requirements of Regu-latory Guide 1.47, " Bypassed and Inoperable Status Indication fcr fluclear Power Plant Safety Systems," to nonitor and verify operations, test and ruintenance activities by neans of an autmntic status noni-toring systen such as that described in Regulatory Guide 1.47. This study is to be perforned following a review of procedures and other nonautonatic actions to verify these activities.
'Ihe Staff position with respect to backfitting Regulatory Guide 1.47 at M-1 will be developed in 1982, or later, subsequent to cmpletion j
of the aforenentioned study.
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Q.
6.
khat action does the staff consider necessary pending development of the staff position on backfitting Regulatory Guide 1.47?
l l A.
Its I.C.6 of the IRC Task Action Plan, NUREG-0660, requires that the licensee's procedures be reviewd and revised, as necessary, to assure that an effective systen of verifying the correct perforrnnce of opera-ting activities is provided. In the clarification letter of Sept aber 5, 1980 (D. G. Eisenhut to All Licensees of Operating Plants), an acceptable program for this veriffeationis described, except as noted in the Septmber 5,.1980 letter, in Section 5.2.6 of Draft 3 of AtG 3.2 (ANSI Standard N18.7-1972), " Administrative Controls and Quality Assurance for l
the Operational Phase of Nuclear Powr Plants." he staff will require the licensee to ceply with iten I.C.6 pending development of the staff position on backfitting Regulatory Guide 1.47.
Q.
7.
khat is the frplementation schedule on item I.C.6 of the NRC Task Action Plan?
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A.
We Action Plan provides that the licensee nust complete this iten by January 1,1981, or prior to the receipt of a full power license, which-i ever is later. For 'INI, this is required before restart, he Office of j
i Inspection and Enforcement will audit the implementation of this item.
Q.
8.
What additional staff requirements were issued to address the administra-tive controls on safety-related systems?
c e
A.
he staff requirenents are outlined in IE Bulletin 79-05A, item 10, which states:
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. "10. Review and nodify as necessary your mintenance and test proce-dures to ensure that they require:
verification, by inspection, of the operability a.
of redundant safety-related syst es prior to the rmoval of any safety-related systs frm service; b.
verification of the operability of all safety-related systes when they are returned to service following mintenance or testing; and means of notifying involved reactor operating personnel c.
whenever a safety-related systs is renoved frm or returned to service."
Q.
9.
Has the licensee complied with this IE Bulletin it m?
l A.
Yes. 'Ihe details are given in NURFB-0680, "IMI-1 Restart," pages C2-7 and C2-8 (item 10). In part, the licensee has nodified its administra-tive controls in the areas of tagging, log entries, and surveillance testing to ensure redundant safety systes are not sinultaneously re-moved frm service. Equip ent tagging and safety-related systems Eurveillane i.esting will be under the direct control of the Shift Foremtn. 'Ihe Shift Forenan mintains an awareness of systes status through a mndatory shift relief and turnover program which requires l
, a review of the station logs. 'Ihe nodified tagging procedure, AP 1002,
" Rules for the Protection of Fmployees Working as Electrical and Mechan-ical Apparatus," requires that rewndant safety-related systems be tested for operability prior to removal of equipment from service. 'Ihis proce-dure also requires the Shift Supervisor to sign tagging applications that remove these systems fran service.
In addition, log entries nust be unde when equipment required by Technical Specifications is taken out of ser-vice or returned to service. 'Ihose systems, permitted in a degraded node of operation by the Technical Specifications, will be noted on the shift turnover checklists which are reviewed by the Shift Foreman. Addi-tional information on the use of shift turnover checklists is given in NUREG-0680, "IMI-1 Restart", pages C8-S4, and C8-55. Based upon the Shift Forman's awareness of plant status and the procedural and Techni-cal Specification requirements, redundant safety systems should not be removed from service simultaneously.
Q.
10.
Have other controls been required by the staff to ensure proper safety system alignment?
Yes. Additional controls were required by IE Bulletin 79-05A, iten 5, and NUREG-0578, item 2.2.1.c.
IE' Bulletin 79-05A, itan 5, states, in part:
" Review all safety-related valve positions and positioning requirements to assure that valves are positioned (open
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. or closed) in a m nner to ensure the proper operation of engineered safety features. Also review related procedures, such as those for mintenance and testing, to ensure that such valves are returned to their correct positions following necessary mnipulations."
The additional controls delineated in NUREG-0578, iten 2.2.1.c, require the licensees to review, and revise plant procedures as necessary to assure that a shift turnover checklist is provided and canpleted by the on-coming and off-going individuals responsible for cocmand of operations in the control roan.
Q.
11.
Has the licensee complied with these additional controls?
A.
Yes. The details are given in NUREG-0680, "IMI-1 Restart," pages C2-5 and C2-6 (iten 5) and pages C8-54 and C8-55 (iten 2.2.1.c).
The licensee has revised the procedures to ensure that proper valve positions in safety-related systems are consistent with the process flow diagram and are m intained during power operations and after mintenance and testing. The revised procedures also require an i
independent reverification of valves and switches m nipulated during the test and mintenance.
In addition, a conplete safety-related valve lineup per the systen operating procedure lineup checklist will be performed prior to startup.
c The licensee has revised the administrative procedures to incorporate Shift 7brnover and Engineered Safeguards checklist to be reviewed by incoming and off-going control room operators, shift formen and shift supervisors.
Q.
12.
How will these controls ensure that an operator is informed that a safety syst m has been disabled?
A.
These controls will require that operators review the readiness of safety-related systems on a shift basis via checklists. This checklist review will ensure that the operator is aware of the status of all safety-related systems.
Q.
13.
Do these measures described above provide information on safety-related syst s status equivalent to that which would result fra conformance to Regulatory Guide 1.47?
A.
tb.
Q.
14.
In what respect do the m asures described above not provide information equivalent to that provided by conformance with Regulatory Guick ' '#.
A.
R.egulatory Guide 1.47 requires that an automatic syst n be provided to,
indicate, on a systen level, the bypassing or deliberately induced in-operability of a safety-related system, whereas the masures being inple-mented at IMI are administrative in nature.
In addition, the licensee's
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controls do not require tagging (indication) at a systm level. However, to provide operator awareness of system bypass at the syst a level, the licensee relies on tagging at a cmponent level supplemnted by notations in the station log books and shift turnover checklists.
An operator's mndatory review of these logs and checklists, in conjunc-tion with his knowledge of syst e desip and compone'at interactions, will provide awareness of the bypass or inoperability o'. equiprent at a systm level.
Q.
15.
Why are these administrative controls sufficient to allow restart without confornance to Regulatory Guide 1.47 or equivalent?
A.
Since the issuance of Regulatory Guide 1.47, and prinarily since the 'IMI-2 accident, the administrative controls over safet"-related systems have been strengthened considerably. 'Ihe areas in which controls have been upgraded i
include:
(1) Verification of safety-related systs aligment during normal operations (2) Approvals required to reove equipment frm service; (3) Monitoring of equipment while out of service;
{4) Reverification of proper safety-related systs aligment after i
naintenance and testing; and (5) Periodic audits to review the effectiveness of administrative l
controls.
r 9-The specific changes rede to the administrative procedures at 'DfI-1 in these five (5) areas are outlined below.
(1) Verification of safety-related systen alignmnt during nonnal operations -- The licensee has mdified Administrative Procedure 1012, " Shift Relief and Iog Entries," to include an E.S. check-list of valves, breakers and switches frcn the control room.
This check will be performed on every shift.
In addition, m nual valves in the min flow paths of engineered safeguards and emer-gency feedwater systens will be checked at least daily by the auxiliary operator and recorded on a logsheet.
AP 1012 also requires the completion of shift turnover checklists j
l for the Shift Supervisor, Shift Foreman and Control Room Operator.
'Ihese checklists identify the status of E.S. equipment, Technical Specification action itens, abnonnal lineups and planned operations.
Thus, AP 1012 will assure ronitoring of E.S. equipent for normal aligment and will assist in the notification of operating person-nel d en this equipment is out of service.
(2) Approvals required to remove equipment from service -- The licensee has mdified the administrative procedures controlling the renoval
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of equipment from service for mintenance and testing. AP 1002, y the switching and tagging procedure, requires the Shift Forenan to approve the tagging (remval) of equipment and also st'ates that redundant engineered safeguards equipment nust be tested prior to
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, r eoval of equipment fr a service. To ensure proper safety-related syst s operability during testing, the revised surveillance tests on safety-related systes have been revised to require Shift Fore-man approval prior to testing.
In addition, these tests regelra a check of the redundant safety systs for operational prior to testing.
(3) Monitoring of equipment while out of service -- As noted in (1) above, the licensee has revised AP 1012 to require the empletion of shift turnover checklists. 'Ihese checklists will identify any E.S. equipment that is out of service and will also specify the time period the equipment may r eain out of service according to the Technical Specifications. To account for periods of absence from operating duties (leave, training, etc.), AP 1012 requires that relieving individuals review the station logs, records and special instructions which have been generated since their last shift.
(4) Reverification of proper safety-related systs aligment after maintenance and testing -- To assure proper syst s alignment after unintenance, AP 1002 was revised to require that the res-toration switching order (return of equipment to service) be verified by a second person. In addition, a second person will verify proper execution of the switching order. To assure proper systs alignment after testing, the surveillance tests have been revised to include an independent position verification. 'Ihere-
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_ _ _ _. fore, after maintenance or testing safety related systs, energency standby readiness will be verified indepenlently by two individuals.
(5) Periodic audits to review the effectiveness of administrative con-trols -- The licensee will evaluate the effectiveness of these programs by requiring: a) the applicable department heads to periodically review / sign their departments' shift turnover log-sheets and b) the Operation Quality Assurance Department to i
i periodically audit and review the effectiveness of the shift turnovers.
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'Iherefore, even though conformance with Regulatory Guide 1.47 has j
not been achieved, the upgraded administrative controls are ade-quate to provide us with reasonable assurance that operators will know the status of safety-related systens while the study con-cerning the backfitting of Regulatory Guide 1.47 is empleted.
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I PROFESSIO!ML QUALIFICATICNS LIST BRUCE A. BO ER Education June 1971 Received BSNE - University of Virginia June 1972 Received tE2E - University of Virginia Work Experience June 1972 to Virginia Electric and Pcrer Co:npany June 1977 Surry Nuclear Power Station Assistant Engineer - Perfonned startup testing on Unit tb. 2.
Engineer - Assisted the Supervisor-Engineering Services; trained for and received a Senior Reactor Operator License.
Supervisor - Engineering Services - Directed the activities of the onsite engineering staff.
Jane 1977 to Virginia Electric and Power Company Sept mber 1977 Ricxond, Virginia SuperM sor - Nuclear Engineering Services - Directed the ace.cies of the offsite engineering staff in support of Surry Power Station.
October 1977 to U. S. Nuclear Regulatory Comission
'Present Bethesda, Pa".f and l
Reactor Engineer in the Operator Licensing Branch - AdmL7-ister licensing examinations to nuclear power plant and research reactor personnel.
Professional Affiliations Registered Professional Engineer - State of Virginia Member - Arerican Nuclear Society I
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F Participation in M Activities Bruce A. Boger November 1978, April 1980: Administered operator license examinations on Unit One.
November 1978, March 1979, March 1980:
Administered operator license examirations on thit Two.
March - April 1979: Member of the M-2 mergency response team, assisted in the preparation of mergency and contingency procedures.
July 1979 - Present: Menber of the M Technical Support Staff, conducted audit examinations on post-accident installed equipment on M-2.
Also partici-pated in the revies of training and procedures in conjunction 5dth the M-1 i restart programs. 'Ihis included preparation of SER inputs and testirony.
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OUTLINE This testimony of Donald F. Sullivan and Bruce A. Boger contains the NRC Staff's response to UCS Contention 9.
The purpose of this testimony is to demonstrate that, contrary to the assertions made in the contention, a bypass and ino;;erable status indication system meeting the guidelines of Regulatory Guide 1.47 or equivalent is not required to adequately protect the health and safety of the public.
Conclusions to be drawn from this testimony:
-- The design provisions of Regulatory Guide 1.47 are intended to aid operators in maintaining an awareness of the bypass, or other deliberately induced inoperability of safety system (s).
TMI-l is not required to conform to the provisions of Regulatory Guide 1.47.
The Licensee has not volunteered to install a " bypass and inoperable status" system that conforms to Regulatory Guide 1.47.
The Staff is presently conducting a study to determine whether to require plants such as TMI-l to conform to Regulatory Guide 1.47, but a decision will not be made until 1982 or later.
Pending completion of the study and a backfit decision, the Staff has i
required licensees to improve their administrative controls for removing safety systems from service for maintenance and returning them to service.
Met Ed has complied with those requirements at TMI-1.
The strengthened administrative controls do not provide information to the operator equivalent to that which would be provided by conformance to Regulatory Guide 1.47.
The upgraded administrative controls provide reasonable assurance of no undue risk to public health and safety.
O