ML19340D558
| ML19340D558 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/24/1980 |
| From: | Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19340D550 | List: |
| References | |
| NUDOCS 8012310238 | |
| Download: ML19340D558 (17) | |
Text
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4 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.
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Docket No. 50-289
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(Three Mile Island, Unit 1)
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TESTIMONY OF RICHARD R. KEIMIG, NRC STAFF, RELATIVE TO MANAGEMENT CAPABILITY TO OPERATE A NUCLEAR GENERATING STATION (ANGRY Contention 4)
Q.1 Please state your name and position with the NRC.
A.
My name is Richard R. Keimig.
I am a Section Chief in the Reactor Opera-tions and Nuclear Support Branch, Office of Inspection and Enforcement, Region I.
Q.2 Have you prepared a statement of professional qualifications?
A.
Yes. A copy is attached to this testimony.
Q.3 Please state your current and prior responsibilities with respect to the Three Mile Island Nuclear Station, Unit 1.
l A.
I am currently serving as the Region I coordinator for the Office of Inspec-tion and Enforcement (IE) activities related to TMI-1.
These activities include this proceeding concerning the restart of TMI-1, review of the IE/TMI-1 inspection program implementation and conduct of inspections, i
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2 liaison with the NRC/TMI Program Office, Resident Inspector Office and Office of Nuclear Reactor Regulation, and review of licensee submittals concerning TMI-1.
I am also Chief, Reactor Projects Section No.1, in the Reactor Operations and Nuclaar Support Branch, Region I.
At the time of the TMI-2 accident, this section was responsible for project overview and implementation of the IE inspection program for TNI-1 and 2.
(Information concerning the IE inspection program can be found in Appendix D to NUREG-0680, Supp. No.
i 1, dated November 28,1980.)
Inspection program implementation was assigned to the NRC Resident Office at TMI in early 1980 and is presently being carried out by personnel stationed on site under the direction of the Region I office.
Q.4 What is the purpose of your testimony?
A.
The purpose of this testimony is to discuss ANGRY Contention 4 which states:
"The licensee lacks the management capability to operate a Nuclear Generating Station without endangering the public health and safety.
This fact is conclusively demonstrated by the numerous negligent and imprudent actions committed by the licensee before and during the TMI-2 accident which are enumerated in Appendices IB and IIF of NUREG 0600.
In support of its contentions, ANGRY places particular emphasis on the following:
(a) Loss of an entire safety system, i.e., auxiliary feedwater generator.
(b) Failure over an extensive period of time to correct leakage of reactor primary coolant through the pressurizer relief valve, causing excessive temperatures in the relief valve exhaust to be regarded as
3 a normal operating condition, and thus preventing such temperatures from alerting plant operators as they normally would to the stuck-open position of the PORV valve during the accident.
(c) Throttling of high-pressure injection flow from the Emergency Core Cooling system in total disregard of abnormally low reactor coolant system pressure, and in apparent conformance to an " operating philosophy" concerning actuation of reactor HPI which placed greater emphasis on considerations of convenience and avoidance of down time than on safety."
Q.5 Would you briefly discuss Appendices IB and IIF of NUREG 0600 as they relate to this contention?
A.
ANGRY has based its contention on apparent negligent and imprudent actions which are enumerated in Appendices IB and IIF of NUREG 0600 which documents the NRC Office of Inspection and Enforcement's investigation of the accident at TMI-2 (Inspection Report No. 50-320/79-10).
It should be noted that the cited appendices of NUREG 0600 list potential items of noncompliance with NRC regulations which were identified during the investigation. As a result of additional NRC reviews and because of mitigating circumstances, not all of the potential items identified in NUREG 0600 were found to be items of noncompliance.
The Notice of Violation transmitted to the licensee by letter dated October 25, 1979, from the Director, Office of Inspection and Enforcement contains the actual items of noncompliance which were cited by NRC. Three of these eleven items were later wi hdrawn when they were not found to exist as cited.
This is t
documented in a subsequent NRC letter to the licensee dated January 23, 1980.
However, the three items which ANGRY has emphasized in this conten-tion remain as indicated in NUREG-0600. A summary of the referenced letters, the items of noncompliance cited by NRC, the licensee's responses to the
4 cited noncompliances and NRC's evaluations of the licensee's responses are contained in Appendix A to NUREG-0680, Supp. No. 1, dated November 28, 1980.
Q.6 In general, what is the nature of the items of noncompliance cited by NRC?
A.
As stated in the aforementioned letter of October 25, 1979, the identified noncompliances demonstrated weaknesses in the licensees management controls just prior to and during the TMI-2 accident.
These weaknesses existed mainly in the general areas of: development and review of procedures; adherence to approved procedures and Technical Specification; control of maintenance activities (recordkeeping); training and retraining for emergency and radiation protection personnel; and, implementation of the radiation protection program. These weaknesses caused, contributed to or otherwise impacted adversely on the accident.
Q.7 How has the licensee responded to the cited items of noncompliance?
A.
In a letter of December 5,1979, which responded to the NRC's letter and Notice of Violation arising from its investigation, the licensee committed to changes in management and management controls to upgrade its nuclear program.
It also committed to take corrective actions with regard to the specific items of noncompliance.
In a :ebsequent letter from the licensee
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5 dated July 21, 1980 and in NRC's response letter, dated November 20, 1980, to that letter, the licensee's specific corrective actions with respect to TMI-I are stated.
The NRC's letter also contains clarifica-tions and documents additional corrective action commitments relative to TMI-1.
Evaluations of the proposed corrective actions to enable safe operation of the plant and to provide for the protection of public health and safety have been made by the Staff and found to be acceptable.
A summary of the referenced letters, items of noncompliance cited by NRC, the licensee's responses to the cited noncompliances and NRC's evaluations of the licensee's responses are contained in Appendix A to NUREG-0680, Supp. No. 1, dated November 28, 1980.
The Staff will verify implementa-tion of these actions by the licensee and will monitor their effectiveness prior to the Staff's final determination regarding authorization for restart of TMI-1 and subsequent to restart, should restart be authorized.
Q.8 What specific corrective actions have been taken by the licensee to the cited items of noncompliance?
A.
The licensee's specific corrective actions, already initiated or proposed, and the NRC's evaluation of these actions are discussed, in detail, in Appendix A to NUREG-0680, Supp. 1, dated November 28, 1980 and, therefore, are not restated herein. However, with respect to the three actions emphasized by ANGRY in its contention, the licensee disagreed with NRC's assessment that these actions, in and of themselves, constituted noncompli-ance.
Detailed analyses of these actions, including the licensee's bases
6 for disagreement, are contained in the licensee's letter to NRC dated December 5, 1979. Notwithstanding this disagreement, the licensee also stated corrective actions which, when implemented, provide reasonable assurance that the root probleas have been adequately addressed.
These corrective actions, and the NRC's evaluations thereof, are contained in the licensee's letters of December 5,1979 and July 21, 1980, and NRC's letters of January 23 and November 20, 1980, respectively.
Summaries are also contained in Appendix A to NUREG-0680, Supp.1, dated November 28, 1980.
Q.9 Has the licensee taken any other actions as a result of NRC concerns besides those actions in response to specific items of noncompliance?
A.
It should be noted that although the licensee's corrective actions to specific items of noncompliance are pointed toward correction of those deficiencies, in many cases, the corrective actions are applicable also to more potentially generic problems rather than just the specific problem cited and, thereby, provide strengthened management controls in other areas as well.
For example, relative to isolation of both TMI-2 emergency feedwater flow paths (ANGRY's emphasized item (a)), the licensee will review all surveillance and test procedures, as well as administrative control procedures for the conduct of surveillances and tests, to ensure that, in carrying out any of these procedures, redundant systems opera-bility would never be jeopardized.
In addition, a formal, routine shift 9
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7 check will be instituted for those systems necessary for safe, plant operation. With respect to failing to correct reactor coolant leakage through the pressurizer relief valve and throttling of high pressure injection flow (. ANGRY's emphasized item (b) and (c)), the licensee has instituted integrated training in plant operations, diagnosis of off-normal symptoms, implementation of procedures etc. and has held meetings with the plant operating staff to discuss management commitments in these a reas.
The licensee also has made major changes in the overall management organization involved in its nuclear operations. These changes affect other nuclear facilities, i.e., TMI-2 and Jersey Central Power and Light Company's Oyster Creek Nuclear Generation Station.
The organization changes are discussed in Section III.B.2, 3 and 4 of NUREG-0680, Supp. 1, dated Novr 18, 1980.
Q.10 Do the major organizational changes increase the licensee's management capability to operate a nuclear power plant?
A.
The organizational changes made by the licensee since the TMI-2 accident are an effort to provide strengthened management and technical support for the Three Mile Island Station, including TMI-1.
The major change l
l combined the nuclear oriented technical and management resources of l
l Metropolitan Edison Company (Met-Ed), GPU Service Corporation and Jersey Central Power and Light Company (JCP&L Co.) into a single organizational l
entity identified as the GPU Nuclear Group.
This group, headed by a l
l l
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8 Chief Operating Executive is responsible to the licensee for management
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of TMI-1 restart activities, TMI-2 recovery activities, and to JCP&L Co.
for Oyster Creek operation. This organization change was approved by NRC for implementation on September 15, 1980, as Amendment No. 93 to the TMI-I Technical Specifications.
In making this change, the licensee has increased substantially the total overall management and technical re-sources available for TMI-1 restart. Additionally, experienced managers and professionals have been introduced at both the corporate and plant levels of the organization.
This centralized, nuclear oriented group is expected to provide increased management capability to focus on nuclear operational matters, as well as personnel policies and procedures appli-cable to nuclear activities.
This new organization is being monitored currently by the NRC staff to determine its capability to deal with TMI-1 restart TMI-2, and the activities of the other nuclear plants for which it has responsibility.
This determination will be complete prior to the Staff's decision concerning TMI-1 restart.
Q.11 How is the corporate staff currently organized?
A.
Under an executive office, comprising a chief and deputy chief operating executive, reporting directly to the presidents of the two NRC licensed utilities and the GPU Service Corporation, are corporate level support g
divisions with six functional areas of responsibility.
These are: Tech-l nical Functions; Nuclear Assurance; Administration; Radiological and 8
Environmental Controls; Maintenance and Construction; and, Communications.
9 Q.12 What are the functions of these corporate level support divisions?
A.
The Director Technical Functions provides a centralized, technical capa-bility to support all aspects of nuclear activities.
The Director Nuclear Assurance supports nuclear operations in the areas of quality assurance, safety assessment, emergency preparedness, training and operational safety. The Director Administration is responsible for business manage-ment and administrative support services, including physical protection of TMI-1 (security), for the GPU Nuclear Group.
The Director Radiological and Environmental Controls is responsible for establishing and implementing radiological and environmental policies, practices and procedures for nuclear plant operations. The Director Maintenance and Construction establishes and monitors policies, practices and procedures for maintenance, repair and construction activities, and carries out plant modifications and rajor and specialized maintenance activities.
The Director Communici-tions establishes and implements policies and programs for communications with news media, government and citizens groups during normal and emergency activities.
In addition to the specific functions stated above, these support divisions are intended to provide technical reviews and operational trend analyses, independent of the on-site TMI-I staff. Also, the licensee intends to implement the following two review groups:
Independent Onsite Safety Review Group (IOSRG):
this is a group of multi-disciplined, technical personnel, assigned at the TMI-1 site but reporting to the corporate level Nuclear Assurance Division.
10 This group will review safety significant plant operations procedures for technical adequacy and clarity, e';aluate operations from a safety perspective and review proposed changes to the facility, technical specifications, tests and experiments, and unreviewed safety matters as well as other NRC regulatory matters.
General Office Review Board (G0RB):
this is a multi-disciplined, senior level, overview group, reporting to the Chief Operating Executive, with responsibility to anticipate potentially significant nuclear safety and radiation problems and recommend measures to avoid or mitigate such problems.
The GORB has a permanent, full-time Chairman and a permanent Vice-Chairman (who is also the Manager, Nuclear Safety Assessment Division). About nine additional members, assigned to TMI-1 matters only, complete the group.
The Chairman and Vice-Chairman also serve in similar capacities on the GORB's for TMI-2 and Oyster Creek.
Q.13 What organizational changes have been made at the TMI-I plant level?
A.
At the plant level, the line management responsibilities, i.e., the operation and maintenance for TMI-1 and TMI-2 has been separated completely.
Operation of THI-1 is under the full-time, on-site, direct supervision of the Director, TMI-1, who reports to the Executive Office of the GPU Nuclear Group.
Reporting to the Director TMI-1 is the Manager Unit 1 -
11 who is responsible for plant operations and maintenance activities; the Manager Plant Engineering - who directs a group of engineers disciplined in nuclear, mechanical, fire protection, chemistry, electrical and instrument /
controls engineering; and, the Manager Administration and Services - who is responsible for personnel and plant security, budget / cost control and general administration. A Safety Review Manager, currently also reporting to the Director TMI-1, is assigned to review Technical Specification submittals, unreviewed safety questions and ottier nucliar safety significant matters. The licensee intends that the Safety Review Manager will become, in the future, the manager of the 10SRG and will report to the corporate level, Nuclear Safety Assessment Division.
Q.14 What are the specific responsibilities of the Manager Unit I?
A.
The Manager Unit 1 is responsible for the day-to-day operation and main-tenance of the plant only.
The Manager Unit I has been relieved of the responsibilities for directing the administration, training, engineering, radiation protection and chemistry functions by assigning these duties to other managers on site.
Reporting to the Manager Unit 1 is the Operations Supervisor, who directs the six operating shift crews, and the Superintendent of Maintenance, who directs two distinct maintenance groups: one group charged with the conduct of preventive maintenance and another which carries out corrective maintenance.
Both maintenance groups are composed of personnel with specialized expertise in mechanical, electrical and instrumentation / controls maintenance. Also, additional maintenance
12 personnel, reporting to the Superintendent of Maintenance, are assigned on a shift basis.
Q.15 What other plant specific organization changes have been instituted?
A.
On-shift safety support is provided by assigning a degreed engineer with specialized, plant specific, norral and abnormal operations training to each shift.
This Shift Technical Advisor reports to the Manager Plant i
Engineering and provides the operating shift with technical liaison and coordination with the Plant Engineering and Technical Functions staffs.
A Training Coordinator has been assigned to the Manager Unit 1.
His function is to provide liaison between the plant operations and maintenance staff and the Manager of Training, TMI-1 in the GPU Nuclear Group relative to specific and specialized training needs and to coordinate the training activities for these personnel through the Manager Unit 1.
The on-site radiological controls function, under the Manager Radiological Controls - Unit 1, reports off-site to the Director Radiological and Environmental Controls in the GPU Nuclear Group.
Routine day-to-day liaison and coordination of radiological matters with plant operations and maintenance activities are provided through the Director TMI-1.
l The Quality Assurance (QA) staff assigned to the TMI site has been signifi-cantly increased; from about 12 prior to the TMI-2 accident, to about 43
@.-m
t 13 at this time.
The on-site QA staff comprises expertise in diverse areas of QA, e.g. design and procurement, material technology, audits, modifica-tions and operations, and is supported by a significantly increased staff in the corporate QA Department which is part of the Nuclear Assurance Division. An on-site manager, who monitors the overall implementation of the site QA program, reports directly to tile corporate Manager Quality Assurance.
He also interfaces with station nNagement regarding opera-tionally oriented QA matters but is organizational 1y independent from the operating staff.
Q.16 How would you assess the organizational changes made by the licensee as they relate to management capability for an operating nuclear power plant?
A.
The changes effected by the licensee in both off-site and on-site management organizations, combined with the introduction of additional experienced management and professional personnel at all levels of the organization, appear to have increased significantly the licensee's capability to manage the operation of TMI-I in a safe manner and with due regard to the protection of public health and safety.
These changes were initiated at this time, and in large part, as a direct result of the accident at TMI-2 as it became evident to the licensee that its approach to management and management controls, both at the corporate and plant levels, were weak in certain areas and would require substantial t.pgrading if approval for
14 further operation of the plant was sought from NRC.
In addition to others' investigations of the accident, the licensee apparently underto)k extensive reviews of its overall management structure, management organiza-tion for supporting, staffing and operating its nuclear plants and policies and procedures for their operation and has instituted changes as a result of these reviews.
In establishing the revised organization, the licensee has endeavored to provide for adequate on-site management, staffing and expertise to support the day-to-day routine operation of the plant, as well as non-routine and emergency plant operations, while maintaining sufficient off-site (corporate) management and technical expertise to direct and support plant operations both routinely and during periods uf
, non-routine activities.
The organizational changes were made over a period of time, and in several stages, as the needs became apparent as a result of continuing reviews by the licensee.
In September 1980, the NRC, after review and evaluation of these changes, approved the new organization for implementation at TMI-1 for the current status of the plant.
Monitoring of the new organization between then and the time of the licensee's proposed restart of Unit I will provide the Staff with a basis for determining the capability of the organization in managing current plant activities and for projecting its capability if restart is permitted.
This determination is on-going and is being conducted by various offices within NRC in order to ensure that all aspects of the l
reorganization are covered adequately. Additional details concerning the i
15 licensee's management capability and technical competence are contained in NUREG-0680, Supp. 1, dated November 28, 1980.
Q.17 What conclusions can be drawn about the licensee's management capability to operate a nuclear power station based upon the licensee's commitments for corrective actions and changes in the organization, policies, programs and procedures?
A.
The licensee has made and continues to make a sincere effort to correct prior deficiencies in the operation of TMI-1.
The comitments and changes already made and those proposed by the licensee for the restart and future operation of TMI-1 are diverse and significant.
The organization changes made at the corporate and plant level provide an appreciably strengthened management capability.
Also, the introduction of new personnel with varied backgrounds and experience into the organization, at all levels, comple-ments the new organization and increases its technical competence.
Likewise, corrective actions taken and those planned and documented by the licensee relative to previous items of noncompliance cited by NRC, as well as other program changes resulting from licensec and NRC reviews and inves-tigation following the accident, should enable the licensee to operate TMI-1 in a safe manner.
Based upon the licensee's commitments for corrective actions and changes in the organization, policies, programs and orocedures, I
and upon full implementations of these commitments, it appears that the
16 licensee will be capable of operating a nuclear power plant safely and with dus' regard to public health and safety.
However, the Staff will continue to review these matters, inspect implementation on a schedule consistent With the licensee's proposed restart date and monitor the effectiveness of the changes and their interaction with each other.
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'a*ater *.heistry for Nu: lear 2:-er 71 ant -7eeat.ent anc Analysis, Calg:n laterat:ry, Inc.,1954 Li:e rs es :
F:fessic al I. gi et -%:' ear D;iree dng ::sta =f Calif:rMa Sec:nd assistant In;inee*, Stas-Uni bited U.S.C.3.
Third Assistant Engieter, Diesel Unif 2ited, U.S.C.G.
Senter Reactor
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Certi fi u te :
Staff Water Che-:ist. FAST, Inc.
l F*:fessienal Society:
berican Nu: lear Society Ez;erience:
4/78 - Pre-Chief, 2ea:tcr 2*ofacts fect'ce 2esconsi 1[forthe sert projet ars;e er; cf tre MI tes:e: icn ;re;rt for rea:::rs in ;re::crational :esr g, starta; testin;.
anc ;;erational ;nases at resi:er,t anc non -esident ins;e: tar sites.
5/77 - 1/78 Chief, Nuclear " ate-f al Cente:1 Sue:e-t Se:ti:n ( Actin:) -
7em:crar11y ceta11ec to supervise :$e activities of a secticn that previces s ecialized su;(; ort in the area of nuclear aterial c:ntrol and ace:untability. NRO RI)
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2/77 - 4/77 Chief f Nue! car Su::e-t Secticn No. 2 - Rese:nsible for the 6/76 - 10/76 si.;ervision of a secuen trat provices s;ecialtred ss: cort in the and areas of cuality assurance, clan: ;r::edares and c;erator 1/78 - 4/78 requalification training. (hAC:AI) 10/76 - 2/77 Chief, Resetor C:ast u: tion Fr:*ects Sectien fictine):
IerQrar1If ass 1;nes 10 supervise :ne activi*1es of a seC* ion tSat ;rovides ; reject managerent for nuclear oc=er facilities under c:nstruction. (NRC:RI) 12/73 - 6/76 Reactse Inst.cter, seect:r c:estructien 8-:*e:t Sectien -
ans ces:ensi le fer :ne tes:ection of nuclear ren::sr facilities 5/72 - 4/73 uncer c:estructicn. Also, served as 7rinci:a1 Ins;e:: r fcr lead Regien f:r 5%FFS pr: ject. UE0/NE*:RI) 4/73 - 12/73
- eset:r f as:e ::r. Ree:: e Test and Starne trench -
Res:cnstoie f:r ne Ins;ecticn of nucitar reactcr facilities during pre-ocersticeal and start::: testing activities. (AEC:RI) 2/71 - 5/ 72 Se**:
- e e:*: s Ea:' rete, h r s a d :e, be. - tes:cesible fer :ne su:ervist en of a ;r:;e:: gr::.: e ; age: in the re:aratica of system design descriptions, ;re-c;erati r.a1 test and c:erating pr:cedures for nuclear and conventional plant syste-s for a utility nuclear power facility. Also, res:casible for planning and directing the accestance, perfor~ance, pre-operational and startup testing prior to c:=ercial c eration. In addition, served as A/E representative on utility, N555. E/C and A/E joint test grous.
10/55 - 1/71 Seier Oce-sti:=s Acalvst. Fies: At:mic Shi: Tr n es :c et. Tae. -
nes;onsioie for :.e prepara:1on ans auc1:1ng of resciar anc ccnventional plant procedares used abcard the M.S. Savannah and for the analyses of reactor plant operatices Also served as shift Su:erintendent during the vessels firs. refueling and acted as liaison with regulaisry agen-f es and c:ntract:rs.
6/62 - 9/56 See:nd 5 ~51-d !ssistant sect ee
,1. e-f etn Cz :rt-Istranetsen tires - Serve: as laten Su:ervisor a::ar.: 3.5. 5avannar,.
Res >casible for the caeraticn, maintecance, testing and other related activities c:ncerned at:5 the reactor and : nventional pcwer plant. Also served arcard varicus c:r;any vessels with respcnsibility for the ::e-at* n and Sainte*ance of c:nventiceal (f:ssil) ;e.ee plants.
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