ML19340D681

Testimony of Pr Clark Responding to 800306 Order CLI-80-5, Issue 7,Sholly Contention 14(d) & Antinuclear Group Representing York Contention 4,questioning Safety Review of & Operational Advice Re TMI-1

ML19340D681
Person / Time
Site:	Three Mile Island
Issue date:	12/22/1980
From:	Phyllis Clark METROPOLITAN EDISON CO.
To:
Shared Package
ML19340D679	List: ML19340D678 ML19340D681 ML19340D682 ML19340D683 ML19340D684 ML19340D685 ML19340D686 ML19340D687 ML19340D688
References
ISSUANCES-SP, NUDOCS 8101050090
Download: ML19340D681 (12)

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4/lng UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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METROPOLITAN EDISON CCMPANY ) Docket No. 50-289 SP

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(Three Mile Island Nuclear )

Station, Unit No. 1) )

LICENSEE'S TESTIMONY OF PHILIP R. CLARK IN RESPONSE TO CLI-80-5, ISSUE 7, SHOLLY CONTENTION 14(d), AND ANGRY CONTENTION IV (SAFETY REVIEWS AND OPERATIONAL ADVICE) 8 3 0 l o r 00TC)

OUTLINE The purposes and objectives of this testimony are to respond to the seventh issue raised by the Commission in its March 6, 1980 Order, CLI-80-5, as well as the matters raised by Intervenors Sholly and ANGRY in Sholly Contention 14 and ANGRY Contention IV which question whether Licensee has the ability to provide proper safety review of and operational advice regarding TMI-1. The testimony shows that, contrary to the allegations of intervenors Sholly and ANGRY, Licensee has established a safety review organization and program which can effectively monitor and respond to problems experienced at the plant, as well as trends in the nuclear industry. Licensee has significantly expanded its safety review program and the resources devoted to that program. Moreover, the organizations which make up Licensee's safety review groups are composed of highly qualified staff and management. These organizations provide multiple means by which Licensee assures that the safety review program remains independent of other on-going activities associated with TMI-1.

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This testimony, by Mr. Philip R. Clark, Executive Vice President, GPU Nuclear Corporation, is addressed to the following statements:

CLI-80-5, ISSUE 7 Whether Metropolitan Edison has made inadequate provision for groups of qualified individuals to provide safety review of and operational advice regarding Unit 1.

SHOLLY CONTENTICN NO. 14(d)

The Licensee's management capability, in terms of organi-

=ational, staffing, and technical capabilities, is not sufficient. Specifically, the following deficiencies in Licensee's management capability are contended:

d. Licenses has not made sufficient provision for qualified individuals to provide safety review of and operational advice regarding TMI-1.

ANGRY CCNTENTION IV The Licensee lacks the management capability to operate a Nuclear Generating Station without endangering the public health and safety.

The GPU Nuclear Corporation has instituted major organiza-tional and staffing changes in order to provide additional safety review of and operational advice regarding TMI Unit 1.

These changes reflect the Licensee's strong commitment to assuring adequate independent review. Licensee's safety review

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and operational advice programs comply with, and in many cases exceed the requirements of the NRC in this area, i.e., Section 4 of ANSI N18.7-1976 ' endorsed oy Reg. Guide 1.33).

Licensee's program has been developed by senior technical management with many years of experience in nuclear activities within GPU and in a variety of other organizations including j the Navy nuclear program, NSSS suppliers and architect engineer firms. This review included consideraticn of the TMI-2 experience, the many investigations of that accident, related NRC requirements and nuclear industry standards and practices.

Licensee's safety review program also has been reviewed during its development by Licensee's existing safety review groups.

It meets current regulatory requirements and enceeds them in

- important respects.

GPU Nuclear Corporation's safety review program is designed to assure that activities are performed in accordance with company policies and applicable laws, standards, policies, l

i rules, regulations, licenses, and technical requirements; that j propc3ed plant, test, and procedural modifications receive independent review; that events, including those that require prompt reporting to the NRC, are investigated and corrected in i

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a manner which reduces the probability of recurrence  ! such events; and that trends which may not be apparent on a l day-to-day basis or by consideration of individual items are detected and appropriate action taken.

Underlying the safety review and operational advice programs is a strong emphasis on the responsibilities of line functional organizations. These responsibilities include preparation of well thought out, adequate designs, procedures and specifications which provide the needed assurance of safety, which include input from affected organizations such as Radiological & Environmental Control and which meet all Company policies and license and regulatory requirements; and on-going review of plant performance and incidents for areas needing improvement.

1 The improved organizational structure and augmented staffing of these functional organizations are described in other testimony, notably that by R. F. Wilson, H. Hukill, et al. and R. W. Heward et al. As a result of the improved organization and staffing, a sound basis is provided for ensuring that the review program is in f act a Review.

The safety review and operational advice programs are also l

structured so as to assess not only individual items but also whether the work of the functional organizations is being done properly and effectively from a safety standpoint and to identify any needed improvement in how that work is being done.

Further, the safety review and operational advice programs discussed herein are in addition to a substantially expanded Quality Assurance Program which incl'udes all aspects of nuclear activities which are important to safety and which audits all l

such activities including the safety review and operational advice programs themselves.

Licensee's safety review program involves four major elements.

The first element of the safety review program is a 100%

review by someone other than the individual doing the work.

This review is performed on activities important to safety including design work or changes, plant operating, emergency and alarm procedures, radiological control procedures and plant maintenance procedures. The review is completed and any needed changes incorporated before implementation of the item reviewed. Responsibility for assuring adequate review of each type of activity is formally assigned to the appropriate organization. For example, review of plant operating, emergency and alarm procedures is assigned to Technical Functions.

The second element of the safety review program is the Independent On-site Safety Review Group (IOSRG). The TMI-1 IOSRG is responsible only for TMI-1. It has no line responsi-bilities or functions and is devoted solely to safety matters.

It is independent of the plant staff and reports off-site to the Manager-Nuclear Safety Assessment Department. It provides before the fact review of such items as. proposed Technical Specification changer, unreviewed safety questions and other items it chooses, or which are referred to it by the functional l organizations.

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In addition, the IOSRG provides af ter the fact overview of activities important to safety to assess both the adequacy of individual matters and the effectiveness of the preparation and review by the functional groups. It also provides direct observation and surveillance of plant operations and ac-tivities. It has full access to all organizational units and activities and can call on individuals outside the group for special expertise. It consists of a Safety Review Manager who meets the requirements of ANSI 3.1 (1978) Section 4.7, and a minimum of 3 technically qualified individuals meeting Section 4.7.2 of ANSI /ANS 3.1 (1978). The present Safety Review Manager is Mr. Max Nelsor., who is a graduate of the University of Colorado with a degree in physics and has thirteen years of professional experience in nuclear power. Mr. Nelson has been a control room operator, Certified Reactor Engineer and Shift Test Engineer at a test reactor. At GPU, he has been involved principally in the preparation and review of procedures and tests at both TMI units. He is well qualified to head the IOSRG at TMI-1.

The third element of the safety review program is the Nuclear Safety Assessment Department which, under the direction of its Manager, reports directly to the Vice President for Nuclear Assurance.

In addition to overseeing the IOSRG's for TMI-1, TMI-2 and Oyster Creek, the Nuclear Safety Assessment Depar tment through l

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Its headquarters staff assesses all aspects of GPU nuclear activities as well as developments elsewhere in the nuclear industry. It provides the following safety review functions:

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1) An overtiew of activities affecting or potentially affecting safety. This is a broadly defined respon-sibility which involves no specific tasks thus making it possible to assess the adequacy of the entire safety review program and identify areas for improve-ment.

2) A corporate Ombudsman accessible on a confidential basis to anyone in the company having a safety concern he or she considers is not being adequately addressed. The Ombudsman is empowered to investigate such matters, identify any needed action and seek its resolution. He will reply to the individual who raised the matter.

3) An ongoing program to evaluate the technical adequacy and clarity of all procedures important to safe operations of TMI-1.

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4) Staff support to the General Office Review Soard (discussed below).

The fourth element of the safety review program is the General Office Review Board. This is a group of senior level individuals with diverse backgrounds. It reports to and takes i

general direction from the Office of the President but has i

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direct access to the Chief Executive Officer and the Board of Directors. Its charter is broadly defined to encompass cl1 matters potentially affecting safety so as to foresee potentially significant nuclear and radiation problems. This includes the functioning of the safety review process and the adequacy of the Quality Assurance Program. It has no specific assigned tasks and thus is able to devote attention to identifying previously unrecognized safety questions or underlying issues. The Board presently includes eleven members, including five who are not part of the GPU System and thus provide independent input and insights from outside.

There is one individual who serves as a full-time Chairman for three GPU GORBs (TMI-1, TMI-2 and Cyster Creek) and a number of common members on the three boards. Meetings of the TMI-l GORB are held about once every three months. The GORB furnishes recommendations directly to the Office of the President and such recommendations are formally responded to. In addition the GORB provides reports to the CEO and Board of Directors.

As noted above, staff assistance is provided to the GORB to help assure its effectiveness. Cf course, GORB has full access within the GPU organizations as well as the ability to obtain specialized assistance if needed.

Closely related to the safety review program is the operational advice program. Like the safety review program, the operational advice program supplements the responsibility t

of the line functional organizations. These line function responsibilities are assigned to:

1) Plant staff specifically including Operations engineers and Plant Engineering as discussed in testimony of H. Hukill et al.

2) Shift Technical Advisors as discussed in the testi-j many of H. Hukill et al. and R. F. Wilson.

3) The Plant Safety Analysis section of Technical Functions as briefly discussed in the testimony of R.

i F. Wilson. This section reviews all licensee event reports from not only GPU plants but other nuclear plants as well and assigns to responsible line organizations specific review and assessment of corrective action for all operating information I

considered to have applicability to TMI-1.

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In addition to the line function responsibilities, the operational advice program includes review by the TMI-l ICSRG of Technical Specification violations, reportable events and other operating experience from within and outside GPU with emphasis on the adequacy of corrective actions needed and taken or planned for TMI-1; and overview by the GORB of the effectiveness of the utilization of operating experience from within and outside GPU to improve TMI-l operation and ac-tivities.

In summary, Licensee now has strong well-defined safety review and operating advice programs which exceed prescribed

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requirements. The programs have been completely modified and strengthened such that an element by element comparison with earlier programs is not practical. However, major improvements include:

1) A well defined, strengthened, and active role and responsibility for Technical Functions in the ongoing review of safety-related activities at TMI-1. This requires active involvement on Technical Functions' own initiative, not just when asked.

2) A significantly increased Technical Functions staff.

3) The establishment of IOSRG as a full time, onsite group independent of line functions and dedicated to safety matters.

4) The creation of the NSAD, whose mission is to monitor, evaluate, and assure that all activities having the potential for compromising nuclear safety are adequately addressed. This includes headquarters staff with no specific assigned tasks and a formally established Cmbudsman.

5) The strengthening and broadening of the GORB by increasing the number of non-company members, by assigning a senior technical individual as full-time Chairman whose only responsibilities are in the area of GORB activities and by provision of staff support.

Moreover, Licensee has selected conscientiouc and talented people for these organizations, in order to assure that the recommendations of the safety review groups are based on sound technical judgment. We have defined the responsibilities and organizational status of the various entities which comprise Licensee's safety review program in order to assure indepen-dence and to give the various safety groups the authority to funccion effectively. And of equal importance, Licensee has identified to the safety review groups and to the entire organization the importance it places on its safety review program. as well as the necessity that the actions and recc e r mendations of the safety review groups remain independent of the unit's activities, and of non-safety related concerns.

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