ML19350B772
| ML19350B772 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/31/1981 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19350B767 | List: |
| References | |
| NUREG-0680, NUREG-0680-S02, NUREG-680, NUREG-680-S2, NUDOCS 8103230672 | |
| Download: ML19350B772 (20) | |
Text
o NUREG-0680 Supp.No.2 TMI 1 Restart Evaluation of Licensee's Compliance with the Short-and Long-Term items of Section ll of the NRC Order Dated August 9,1979, Metropolitan Edison Company, et al.
Three Mile Island Nuclear Station Unit 1 Docket 50-289 U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation ps" "' coq,
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BIBLIOGRAPHIC DATA SHEET NUREG-0680, Supplement No. 2
- 4. TITLE AND SUSTITLE (Add VWunie Na, a eprene=J Tril-1 RESTART Sub ti t 1:
- 2. It, e oi,* s Evaluation of Licensee's Compliance with the Short and Long Term Items of Section II of the NRC Order Dated August 9,1979, a. RECIPIENT S accession NO.
4etropolitan Edison Company, et al, Three Mile Island Nuclear Station, Unit No.1, Docket 50-289.
- 5. O ATE REPORT COMPLE TED uomTs lvEma March 1981
- 9. FERFORMING ORGANIZATION N AME AND MAILING ADORESS (Incivoe lip Codel DATE REPORT ISSUEO uo~ra jveaa U. S. Nuclear Regulatory Comission March 1981 Office of Nuclear Reactor Regulation Washington, D. C.
20555
- s. (te~e means
- 8. (Leave mann)
- 12. SPONSORING ORGANIZATION NAME AND M AILING ADORESS (include I,a Cooet p
Same as 9 above.
- 11. CONTRACT NO.
Docket No. 50-289 t $. SUPPLEMENTARY NOTES 14./teave W e s/
- 16. A85TR ACT 200 words or less)
)
This supplement to NUREG-0680 (TMI-l Restart Evaluation) updates our review in the general area of management capability and resources and describes the resolution or status of unresolved items noted in Supplement 1 which was issued on November 28, 1980.
We conclude that the licensee has made substantial improvements its the area of management capability and resources a'nd that the licensee is in compliance with Item 6 of the August 9, 1979 Order as amplified by the March 6,1980 Order, except for one unresolved item.
- 17. KEY WORDS ANO DOCUMENT AN ALYSIS 17e. DESCRIPTORS 17b. IDENTIFIERSiOPEN ENDEO TERMS S
21 NO OF P AGES
- 20. SECURITY CLASS (T4 s pagr1 22 PRICE S
N: c s o e v 333 e 7 771
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NUREG-0680 Supp.No.2 TMI - 1 Restart Evaluation of Licensee's Compliance with the Short-and Long-Term items of Section ll of the NRC Order Dated August 9,1979, Metropolitan Edison Company, et al.
Three Mile Island Nuclear Station Unit 1 Docket 50-289 Manuscript Cornpleted: March 1981 Date Published: March 1981 Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20556
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ABSTRACT This supplement to NUREG-0680 (TMI-1 Restart Evaluation) updates our review in the general area of management capability and resources and describes the resolution or status of unresolved items noted in Supplement 1 which was issued on November 28, 1980.
We conclude that the licensee has made substantial improvements in the area of management capability and resources and that the licensee is in compliance with Item 6 of the August 9, 1979 Order as amplified by the March 6, 1980 Order, except for one unresolved item.
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TABLE OF CONTENTS Page I.
Introduction..................................................
1 II.
S umma ry a n d C o n c l u s i o n s........................................
1 III. Order Item 6 (Short-term) Management Capability and Resources..
2 B.
Management and Technical Capability.......................
2
~
3.
Onsite Organization and Resources....................
2 a.
Station Organization............................
2 b.
Licensed Operator Status........................
4 5.
Office of Inspection and Enforcement Inspections.....
5 C.
Safety Review and Operational Advice......................
5 E.
Operational Qual i ty Assurance Program.....................
6 F.
Facility Procedures.......................................
6 G.
Health Physics............................................
7 1.
Response to Commission Order of March 6, 1980 (CL 1-80-5).
7 Order Item 2..............................................
7 Order Item 3..............................................
7 Order Item 4..............................................
8 Order Item 5..............................................
8 Order Item 7..............................................
8 Order Item 10.............................................
9 Order Item 12.............................................
10 J.
Conclusions...............................................
10 IV.
Compliance with NUREG-0694 Requirements (Management Area)......
12 V.
Errata (NUREG-0680, Supplement 1)..............................
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I.
INTRODUCTION The Nuclear Regulatory Commission's TMI-1 Restart Evaluation (NUREG-0680) of the compliance of Metropolitan Edison Ccmpany et al., with the short-and long-term items of Section II of the NRC Order dated August 9, 1979 was issued on June 16, 1980. We concluded that for a significant majority of individual items and subitems of the Order, the licensee was in compliance but that review was continuing on the remaining open items.
On March 6, 1980, the Commission provided further guidance regarding the issues of management capability and resources in Order CLI-80-5.
Supplement 1 to our TMI-l Restart Evaluation (Evaluation Report) was issued on November 28, 1980.
Supplement 1 dealt primarily with issues or requirements relevant to the management area.
In Supplement 1, we concluded that the licensee had made substantial improvements in the area of management capability and resources and was continuing its efforts in this direction. A few items in the general management area were unresolved at the time of issuance of Supplement 1.
The purpose of this supplement to the Evaluation Report is to update our review in the general area of management capability and resources and to describe the resolution or status of unresolved items noted in Supplement 1.
Our evaluation in this Supplement is presented in the same table of contents format as Supplement 1 to the Evaluation Report.
II.
SUMMARY
AND CONCLUSIONS Based upon our review of additional information and documentation as described herein, we conclude that the licensee has made substantial improvements in the area of management capability and resources and that the licensee is in com-pliance with Item 6 of the August 9,1979 Order as amplified by the March 6, 1980 Order, except for the item identified in Section III.E. herein (Q-list).
Item 12 of the March 6, 1980 order concerning the licensee's financ1d resources will be considered as part of Item 7 of the August 9,1979 Order which specifically addresses financial capability.
The Staff's evaluation of financial capability l
will be included in a supplement to the Evaluation Report.
The licensee's implementation of and compliance with commitments discussed in the Evaluation Report and Supplements, including effectiveness of management improvements, will be verified during the TMI-1 Restart Inspection Program described in Appendix D of Supplement 1.
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i III. ORDER ITEM 6 (SHORT-TERM) MANAGEMENT CAPABILITY AND RESOURCES B.
MANAGEMENT AND TECHNICAL CAPABILITY
- 3. Onsite Organization and Resources a.
Station Organization In the TMI-1 Restart Evaluation Report (NUREG-0680, Supplement 1),
at pages 10, 24, and 38, we stated that the staff had not completed its review of the licensee's program for the training of unlicensed personnel.
Specifically, we were awaiting further description of the licensee's Training Department and the development of training procedures. We also stated that the training program should be approved and implemented prior to restart of Unit 1.
Additionally, the report of the Performance Appraisal Branch of the Office of Inspection and Enforcement (Special Management Appraisal - IE Inspection Report 50-289/80-21), described in Appendix B to Supplement No. 1 of NUREG-0680, identified weaknesses in the area of nonlicensed personnel training (see page 9, Appendix B).
By letter dated November 26, 1980, the licensee responded to the PAB team comments, and itemized the training programs for nonlicensed personnel that had been developed and were in use.
These are:
Maintenance Technicians (since 11/79)
Radiological Controls Technicians (since 1/80)
Chemistry Technicians (since 5/80)
Initial training for Radiological Controls Technicians (since 2/80)
Initial training for Chemistry Technicians (since 6/80)
Emergency Response Training (since 12/79)
Rad Waste Administration and Handling (since 12/79)
Shift Technical A41 visor Program (since 12/79)
Decision Analysis Program (since 3/80)
Instructor Development Program (since 8/80)
Since publication of Supplement No. 1 to NUREG-0680, we have had an opportunity to review the organizational structure and staffing for training of TMI-1 personnel. A corporate Director - Education and Training coordinates the training for all of the GPU nuclear plants and provides necessary training to corporate level personnel.
The TMI-1 Training Department has a staff of 45 people, operating under the direction of a Manager of Training.
Incumbents in both of these positions are professional educators with solid backgrounds in nuclear training. We have reviewed the structure and staffing for training in support of TMI-1 as described below and we conclude it is acceptable.
The licensee has stated that the THI-1 Training Department is sub-divided into four sections:
Operator Training, Technician Training, Training and Educational Development, and Administrative Support.
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Training of auxiliary (nonlicensed) operators is conducted by the Operator Training Section.
For entry into the auxiliary operator training program, an individual must be a high school graduate or hold an equivalency certificate.
Applicants are interviewed to determine their maturity and their potential for advancement.
The training program is two years long with about one year of formal classroom instruction followed by about one year of on-shift, on-the-job (0JT) training and experience.
The trainee must satisfactorily complete the entire two year program prior to classification as a fully qualified auxiliary operator.
The classroom instruction includes courses in nuclear power orientation, basic math, basic nuclear concepts, reactor physics, fundamentals of heat transfer and fluid dynamics, mechanical equipment construction / operation, radiation protection, chemistry and water / waste treatment, electrical funda-mentals, instrumentation and operational analysis, procedures, fire brigade training, plani safety, and the primary and secondary systems of the reactor.
Examinations are given following each topical section and a comprehensive examination is given at the end of the course. Upon successful completion of classroom training, the trainees then spend about six months in w T on plant secondary systems and an additional six months in OJT on plant primary systems.
Additional examinations are given toward the end of each OJT period.
Once the auxiliary operators complete their initial training, they then participate in one week of retraining during each six week shift cycle for the duration of their assignments as auxiliary operators.
We have examined the description of the auxiliary operator training and qualifications and have compared it to the guidance in the Second Proposed Revision 2 to Regulatory Guide 1.8.
We find that it meets the guidelines and is acceptable.
Technician training is conducted by the Technician Training Section.
The Maintenance Technician Training Program is designed around a six shift schedule and provides for up to 320 hours0.0037 days <br />0.0889 hours <br />5.291005e-4 weeks <br />1.2176e-4 months <br /> of training and retraining each year.
The first two years of the program are designed to provide a progressive update for the technician by review of basic concepts and basic skills and to provide instruction in plant systems and advanced specific systems, components, and concepts.
During the first section of the basic training phase, all maintenance personnel are given a self-study course consisting of fundamental lessons on maintenance tools and the major principles involved in mechanical, electrical, I&C, and general maintenance work. Quizzes are given and there are provisions for repeating the work if needed.
The second part of the first year is subdivided between systems training and training in the specific discipline of the technician.
The second year of training follows a similar pattern as the first year, but at a more advanced level.
Subsequent training cycles will continue the progression, and are aimed toward assuring that the technicians maintain capable technical and professional abilities.
Radiological control technicians and chemistry technicians receive an initial training program of about eight weeks and six weeks, 3
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respectively, prior to receiving shift assignments.
These initial training courses are designed to ensure that these technicians understand the basics for operation in their respective areas.
Following the initial training, these technicians also participate in a cyclic training program where one week of each six week shift cycle is spent in training, designed to progressively upgrade their capabilities and to assure that they remain competent in their technical abilities.
We have reviewed the description of the training programs for plant technicians, have compared these descriptions with the guidance contained in the Second Proposed Revision 2 to Regulatory Guide 1.8, and find them to be acceptable.
In Supplement No.1, we stated that the licensee had not developed procedures covering the training at TMI-1.
The licensee has now issued a training manual for THI-1 which contains these procedures.
This manual is under review oy the Office of Inspection and Enforce-ment and we will assure its adequacy prior to any recommendation for restart of TMI-1. We conclude, therefore, that this matter is acceptably resolved.
la summary, our review of the licensee's program for training of nonlicensed personnel indicates that those persons whose activities could have an impact on safe plant operation will be well qualified.
Accordingly, we find that the training program as described by the licensee is acceptable.
Subsequent inspections by IE will verify the continued and effective implementation of these training programs.
We therefore consider this matter to be resolved.
b.
Licensed Operator Status In the TMI-1 Restart Evaluation Report (NUREG-0680, Supplement 1) at pages 11 and 38, we noted that the licensee had not informed us of his plans for training additional licensed operators. We stated that we had requested this information from the licensee and that, l
prior to a recommendation for restart authorization, we would assure that the licensee had made adequate plans for training additional R0s and SR0s for the long term.
The licensee responded to our request by letter dated February 6, 1981.
In the letter, the licensee stated that TMI-1 now has 22 l
Control Room Op:rators, seven Shift Foremen, and six Shift Supervisors.
l The six Shift Supervisors and four of the Shift Foremen now have SRO l
licenses. Three of the Shift Foremen now have R0 licenses, but will be taking the examination for SRO.
Ten of the Control Room Operators now have R0 licenses.
An additional seven will be taking the R0 examination.
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A total of 17 individuals will be taking the NRC licensing examination for R0 prior to restart of Unit 1.
In addition, 18 individuals will l
take the SR0 examination prior to startup.
Five of these 18 are on the training and operations staffs, however, and would not normally
be available for shift work.
The number of operators taking the relicensing examination should be sufficient to assure that the licensee will have the minimum numoer of operators needed to staff a five-shift operation (10 R0s and 10 SR0s).
The licensee also stated that the current authorized manning for the plant permits 12 individuals to be in training for SR0/R0 licenses while still manning each shift with two SR0s and two R0s. As vacan-cies occur, additional personnel will enter the established licensed operator training program.
Based on our review of this information, we conclude that the licensee has made adequate plans for training of licensed operators for the long term and we therefore consider this matter to be resolved.
- 5. Office of Insoection and Enforcement Insoections In the conclusions portion of Section III.B.5 of Supplement 1 to the Evaluation Report, page 18, we noted the licensee had not responded to our management appraisal and health physics evaluation. We indicated we would evaluate the licensee's responses for adequacy and verify corrective actions prior to restart.
The licensee has responded to the noncompliances and significant weaknesses identified during the past management appraisal and health physics evaluation, in the areas of committee activities, nonlicensed technical training, radiation protection (radiological controls) and emergency planning.
The licensee's responses were evaluated by the NRC Region I Office of Inspection and Enforcement Staff and were considered acceptable.
The licensee's reported corrective actions, either taken or planned, include implementation of a Plant Operations Review Committee (PORC) Charter, implementation of Generation Review Committee functions for TMI-1, development and implementation of a Training Department Administrative Manual, and cefinition of the Nuclear Assurance Division and the Radiological Controls and Environmental Division organization structures, respon-sibilities and functions, plus numerous specific organizational and procedural improvements. These corrective ceasures, when fully implemented, are sufficient to resolve the management concerns identified during past IE inspections.
Region I will verify satis-factory implementation of the various corrective measures including effectivaness of management improvements, prior to TMI-l restart.
C.
SAFETY REVIEW AND OPERATIONAL ADVICE In the TMI-l Restart Evaluation Report (NUREG-0680, Supplement 1) at pages 21, 27, 38, and 43, we stated that we had reviewed a draft Engineering Procedure, EP-013, " Industry / GPUNG Operating Expcrience Reviews" and TMI-l Administrative Procedure, AP-1032, " Dissemination of Information" which together described the program to be used by the licensee for the collection, evaluation, and dissemination of operating experience information. We also stated that we would review these procedures again when EP-013 had been formally issued to assure that adequate provisions had been made for feecback of operating experience.
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EP-013 has now been reissued as EP-030, " Review of Industry /GPUN Operating Experience," Revision 0, dated December 22, 1980. Our understanding is that in the next few months it will he issued in final form as EP-017 as part of a reordering of the procedure numbering system.
In the meanwhile, we have examined EP-030 and we find that, in conjunction with AP-1032 and other referenced procedures, it makes adequate provisions for the collec-tion, evaluation, ad dissemination of operating experiences.
IE will review the final version of the procedure to assure that the provisions for handling the operating experience information are not degraded from those now contained in EP-030.
We conclude that the licensee has made adequate provisions for the feedback of operating experience information and we therefore consider this matter to be resolved.
E.
OPERATIONAL QUALITY ASSURANCE PROGRAM In Supplement 1 to the Evaluation Report, we indicated that this section remained unchanged from the description in the Evalue' ion Report. On page C6-12 of the Evaluation Report we noted that the quality assurance program has been extended to apply to all structures, systems, components, and activities important to safety as indicated in Regulatory Guide 1.29, Appendix A of 10 CFR 50 and Appendix E of 10 CFR 71, subject to receipt and approval of identification of structures, systems, and components, under the control of the QA program. The list'of systems, components, and structures to which the QA program is applicable (Q-list) has been prepared by the licensee. We are reviewing the Q-list to verify its acceptability.
F.
FACILITY PROCEDURES In Supplement 1 to the Evaluation Report, page 22, we noted that 16 TMI-1 procedures required revision as a result of a second staff review.
Discussions with the licensee led to a commitment to incorporate the staff's comments. Accordingly, the licensee revised, or initiated revision re,uests for, these procedures. We will verify that these procedure revisions have been incorporated prior to any restart of the facility.
Copies of the revised procedures that are applicable to operating personnel will be placed in the revision review book which is reviewed by operating personnel as part of the normal shift turnover procedure.
Therefore, based upon our review of the procedures previously revised and the licensee's commitment to complete the remaining procedure revisions, we find that the licensee is making acceptable provisions for procedure review and revision and operator notification of procedure revision.
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Additional review of selected emergency procedures will be conducted in accordarce with NUREG-0737, Clarification of Action Plan Requirements, t
Item I.L.8, Pilot Monitoring of Emergency Procedures, as clarified in the January 28, 1981 letter from D. G. Eisenhut to H. D. Hukill.
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G.
HEALTH PHYSICS In the Evaluation Report Supplement 1, we noted that the results of an evaluation of the health physics program at the Three Mile Island Nuclear Station had been issued as Inspection Report 50-289/80-22. We evaluated the licensee's response to the significant evaluation findings and items of noncompliance specified in the report and issued our conclusions on March 19, 1981.
The licensee has committed to propose a technical specifi-cation change which will require radiological control technicians to either-meet the qualifications of ANSI-18.1-1971, Paragraph 4.5.2, or to be formally qualified through an NRC approved TMI-1 Radiation Technician Training Program.
We conclude that no outstanding issues remain regarding the management and technical capability in the health physics area and training of radiological controls staff, subject to satisfactory implementation as discussed in Section III.B.5 above.
I.
RESPONSE TO COMMISSION ORDER OF MARCH 6, 1980 This section of Supplement 1 to the Evaluation Report is modified to incorporate the additional information specified below for Order Items 2, 3, 4, 5, 7, 10 and 12.
Order Item 2.
"Whether the operations and technical staff of Unit 1 is qualified to operate Unit 1 safely (the adequacy of the facility's maintenance program should be among the matters considered by the Board)."
On page 24 of Supplement 1 to the Evaluation Report we noted that our review of the training program for nonlicensed personnel was incomplete.
Based on our review of additional information regarding the training of nonlicensed personnel is described in Section III.B.3.a herein, we conclude that the training program as described by the licensee is acceptable. We therefore consider this item to be resolved.
Order Item 3.
"What are the views of the NRC inspectors regarding the quality of the management of TMI Unit 1 and the corporate management, staffing, organization, and resources of Metropolitan Edison."
In Supplement 1 to the Evaluation Report, page 24, we included a summary of the inspector's views as of November 1980.
Since that time, the licensee has responded to noncompliances and significant weaknesses identified during the management appraisal and health physics evaluation.
We conclude that the corrective measures proposed by the licensee, when fully implemented, are sufficient to resolve the management concerns-identified during past IE inspections.
Region I will verify satisfactory implementation of the various corrective measures, including effectiveness of management improvement, prior to TMI-1 restart.
Refer to Section III.B.5 above for additional information.
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I Order Item 4.
"Whether the Unit 1 Health Physics program is appropriately organized and staffed with qualified individuals to ensure the safe operation of the facility."
In Supplement 1 to the Evaluation Report, page 24, we indicated that the licensee's response and our evaluation of the management-related issues in Inspection Report 50-289/80-22 were incomplete.
Section III.G above notes that our evaluation of the licensee's response to Inspection Report 50-289/80-22 was issued on March 19, 1981. We conclude that the TMI-1 Health Physics program will be appropriately organized and staffed, based upon our earlier review, the licensee's response to Inspection Report 50-289/80-22, and the commitment to request a technical specification change with respect to qualification of the radiological control technicians. We consider this item to be resolved and will verify satisfactory implementation of the corrective actions during subsequent NRC inspections, prior to TMI-1 restart.
Order Item 5.
"Whether the Unit 1 Radiation Waste system is appropriately staffed with qualified individuals to ensure the safe operation of the facility."
In Supplement 1 to the Evaluation Report, page 25, we noted that the staffing, qualifications, and training of the chemistry personnel had not been evaluated. As noted in Section III.B.3.a above, our review of the licensee's training program, which includes chemistry personnel, indicates that those persons whose activities could have an impact on safe plant operation will be well qualified.
In Supplement 1 to the Evaluation Report, page 26, we indicated that based on the review of the Radioactive Waste Management Program, it appears that the Unit 1 organization is appropriately staffed with qualified personnel, but that the interface between the Unit 1 and 2 radioactive waste organization and the training and retraining program for nonlicensed personnel were not documented.
The licensee's response to inspection Report 50-289/80-22 reported corrective actions, either taken or planned, which included interfaces and radwaste training /
retraining programs for TMI-1 and 2.
These corrective measures, when fully implemented, are sufficient to resolve the previous significant weaknesses.
Region I will verify satisfactory implementation of the corrective measures prior to TMI-1 restart.
l Order Item 7.
"Whether Metropolitan Edison has made adequate provision for groups of qualified individuals to provide safety review of and operational advice regarding Unit 1."
On page 27 of Supplement 1 to the Evaluation Report, we indicated that verification uf the adequacy of procedures EP-013 and AP-1032 was required.
Section III.C. herein describes our review of procedures EP-013 and AP-1032. We conclude that the licensee has made adequate provisions for the feedback of operating experience information and we therefore consider this matter to be resolved.
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Order Item 10.
"Whether the actions of Metropolitan Edison's corporate or plant management (or any part or individual member thereof) in connec-tion with the accident at Unit 2 reveal deficiencies in the corporate or plant management that must be corrected before Unit 1 can be operated safely."
In Supplement 1 to the Evaluation Report, on pages 36 and 37, we referred to an ongoing investigation by the Office of Inspection and Enforcement related to information transfer during the March 28, 1979 accident, and indicated that a report would be issued upon completion of the investigation.
The report, NUREG-0760, Investigation into Information Flow During the Accident at Three Mile Island, was issued on January 27, 1981.
This investigation found that although pertinent information was not intention-ally withheld on March 28, 1979, information was not adequately transmitted to the NRC or the Pennsylvania Bureau of Radiological Protection.
NUREG-0746, Emergency Preparedness Evaluation for TMI-1, assessed the licensee's communications facilities and plans for communications flow during an accident in accordance with the requirements of 10 CFR 50.47 and the guidance in NUREG-0654.
The problems with communications and information flow identified during the TMI-2 accident were reflected in the revised emergency planning regulations and as such the recommendations subsequently contained in NUREG-0760 had already been considered.
The licensee's corrective actions relative to the items of noncompliance cited in the Notice of Violation included in the January 27, 1981 trans-mittal will be reviewed as part of the NRC's evaluation of the licensee's emergency preparedness. When the licensee's implementation of their revised emeegency plan, revised in conformance to the guidance in NUREG-0654, is reviewed during an emergency preparedness exercise, the adequacy of the corrective actions will be verified. There are no management, organization, or staffing issues addressed in NUREG-0760 for which additional licensee action has been identified.
In Supplement 1 to the Evaluation Report, we also presented a brief description of a separate investigative effort conducted by the Department of Justice (00J) in response to concerns raised regarding possible falsi-fication of Reactor Coolant System (RCS) leak rate test data for Unit 2.
That investigation was initially undertaken by NRC and identified a number of apparent problems related to procedure adherence.
NRC's investi-gative effort was suspended pending the conclusion of the 00J investigation, at their request, to avoid parallel administrative and criminal proceedings.
The 00J investigation is still ongoing, and the NRC does not possess any information as to when it may be completed.
NRC personnel involved in the suspended investigation have been requested by D0J not to discuss the details of the matter.
Since completion of the investigation of this matter by the NRC could turn up information which is related to past management practices, the matter was included in Supplement 1 to the Evaluation Report.
The NRC will resume its investigation of the concerns d en 00J has completed its investigation of the matter.
However, the staff has reviewed the information that it has obtained to date on the matter, and has concluded on the basis of information thus far obtained that there appears to be no direct connection with the Unit 2 accident.
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Further, although the NRC investigation is not complete, and the examination of Unit 1 records was limited, no indication of practices at Unit 1 similar to those alleged at Unit 2 were identified.
In light of the licensee's clear management policy regarding strict adherence to procedures which was stated in a memorandum from the licensee's Office of the Chief Operating Executive communicated directly by face-to-face discussion between management and plant personnel, and recently formalized by incorporation into the Conduct of Operations Manual, the establishment of a management policy for disciplinary measures to be taken for failure to adhere to procedures, and the establishment by the licensee of an operations inspection program to verify procedure adherence, the staff believes, based upon our current knowledge, the identified con-cerns appear to be only of historical significance.
Nevertheless, NRC inspectors will be alert to procedure adherence problems in general, and accuracy of RCS leak rate testing data specifically, should the facility be permitted to restart.
In conclusion, based on our reviews as discussed herein, we conclude that deficiencies in the licensee's corporate or plant management revealed by investigation of corporate or plant management actions in connection with the Unit 2 accident have been corrected or have been identified for correction prior to restart of Unit 1, and consider this matter resolved.
Order Item 12.
"Whether Metropolitan Edison possesses the financial resources necessary to safely operate Unit'l in addition to cleaning up Unit 2."
This item will be considered as part of Item 7 of the August 9, 1979 Order which requires that the licensee demonstrate his financial quali-fications.
Our evaluation of the financial issue will be contained in a supplement to the Evaluation Report.
J.
Conclusions The paragraph in this section on page 38 of Supplement 1 to the Evaluation Report is deleted and replaced by the following:
Based upon our review of additional information and documentation as described herein, we conclude that the licensee has made substantial improvements in the area of management capability and resources and that the licensee is in compliance with Item 6 of the August 9, 1979 Order as amplified by the March 6,1980 Order, with the exception of the item identified in Section III.E. herein (Q-list).
Item 12 of the March 6, 1980 order concerning the licensee's financial resources will be considered as part of Item 7 of the August 9, 1979 Order which specifically addresses financial capability.
The Staf f's evaluation of financial capability will be included in a supplement to the Evaluation Report.
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J The licensee's implementation of and compliance with commitments discussed in the Evaluation Report and Supplements, including effectiveness of management improvements, will be verified during the TMI-1 Restart Inspec-tion Program described in Appendix 0 of Supplement 1.
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IV.
COMPLIANCE WITH NUREG-0694 REQUIREMENTS (MANAGEMENT AREA)
Modify page 45 of Supplement 1 to the Evaluation Report as stated below.
1.
II.B.4 Training for Mitigating Core Damage The following snould be added to the Discussion Section of this item; On January 21, 1981, the licensee submitted an outline of the training program it will administer to satisfy this requirement.
The pilot course is to be conducted during the week of March 16, 1981.
The following sentence should replace that of the Conclusion Section.
Based on the review of the January 21, 1981 letter and our previous review:, we conclude that the licensee's program for training to mitigate core damage meets the requirements of NUREG-0694, Itsm II.B.4.
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r V.
ERRATA The following corrections have been identified in Supplement 1 to the Evaluation Report (NUREG-0680):
pages 6
Figure III-B-1, under Vice President of Nuclear Assurance the initials should be:
10SRG - Independent Onsite Review Group.
20,21 Substitute the following 2 pages.
Changes to these pages are indicated l'
by marginal marking.
The changes are needed to clarify the intentions of the licensee as we understand them. Overall, these changes have no effect on the conclusions reported in Supplement 1.
23 The PAB report number should be changed to 50-289/80-21 in line 5 from the top and line 4 from the bottom of the page.
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The licensee has established provisions for carrying out safety reviews and audits and is finalizing procedures to provide operational advice to TMI-1.
The provisions for providing safety review and audit will include reviews by three different groups:
the support divisions; an Independent Onsite Safety Review Group (IOSRG); and the General Office Review Board (G0RB), which utilizes the services of the Nuclear Safety Assessment Department (NSAD) of the Nuclear Assu.ance Division.
The support divisions are multi-disciplinary corporate organizations that provide technical review and support of activities at the plant site.
They are independent of the TMI-1 operations staff.
Personnel are pre-vided who perform an independent review of all proposed changes to procedures, the facility, and the Technical Specifications, and of pro-posed license amendments.
This group also conducts a continuing review of overall plant performance and identifies trends. The review for trends includes consideration of violations of requirements, significant ope'ating abnormalities or deviations from expected plant behavior, and events requir-ing notification of the NRC.
Results of the reviews are made directly available to the THI-1 management organization.
Use of the GPU Nuclear divisions in this manner satisfies the provisions of Sections 4.3 and 4.4 of ANS 3.2 (Draft 5) and will eliminate the need for the currently established Plant Operations Review Committee (PORC).
The licensee plans to submit for NRC approval a Technical Specification change request to reflect the revised organizational structure which includes the elimina-tion of the PORC. The replacement of the PORC will enable plant staff supervisory personnel to devote their time to their primary duties without the time-consuming need for participation in PORC meetings, which, under the present organization requires upwards of half of the supervisors' time.
The proposed Independent Onsite Safety Review Group (IOSRG) will satisfy the requirements for an independent, full-time, safety engineering staff to be located onsite.
The IOSRG will be a group of technical personnel who are assigned onsite at TMI, but who report to the corporate level
(
Nuclear Assurance Division. The IOSRG will conduct an ongoing program to evaluate the technical adequacy and clarity of procedures important to l
safe operation of the plant (not necessarily a pre-implementation evaluation).
l It will evaluate TMI-1 operations from a safety perspective.
The IOSRG will also review, when a change to Technical Specifications or an unreviewed safety question is involved, proposed changes to the facility, L and proposed tests or experiments as well as violations, deviations, and other events that are reportable to the NRC.
The IOSRG will advise the Director, TMI-1 and the Manager, TMI-1.
Members of the Nuclear Safety Assessment Department (NSAD) of the Nuclear Assurance Division serve as the staff for the General Office Review Board (GORB).
The GORB is a senior level overview group charged with responsibi-lity to foresee potentially significant nuclear and radiation problems, t
and to recommend to the Chief Operating Executive how they may be avoided or mitigated.
The GORB has a permanent, full-time chairman, a pumanent
i i
! \\
Vice Chairman who is the Manager of the NSAD, and approximately nine addi-tional members whose areas of expertise embrace all aspects of nuclear power plant operation.
The Chairman and Vice Chairman also serve in similar capacities on the GORBs for TMI-2 and Oyster Creek.
The NSAD conducts assessments of all aspects of nuclear power plant design and operation, :onsiders their potential for compromising nuclear safety, and recommends necessary improvements. A unique function of the NSAD is to serve as ombudsman for all members of the corporation having concerns for nuclear safety.
The QA Department and the Director of Nuclear Assurance satisfy t*.e requirements of Section 4.5 of ANS 3.2 for a comprehensive system c r audits.
In addition to the safety review and audit functions described above, the licensee is taking specific measures to assure the proper collection, eval-uation, and dissemination of plant operational experiences throughout the corporate structure and at TMI-1. We have reviewed a draft Engineering Procedure, EP-013, " Industry /GPUNG Operating Experience Reviews," and THI-1 Administrative Procedure, AP-1032, " Dissemination of Information,"
dated August 29, 1977, Revision 0.
EP-013 describes the procedure to be used for the collection, evaluation, and dissemination of operating experience information on GPUNG plan' and at other plants. This procedure, in conjunction with AP-1032, is intended to provide for the collection and evaluation of operating experience information and the dissemination of this information to the appropriate parties both at TMI-1 and within the corporate structure.
EP-013 is scheduled to be issued formally in January 1981.
We will review EP-013 when it is issued, in conjunction with AP-1032, to assure that adequate provisions have been made for the collection, evaluation, and dissemination of operating experience information.
Based on our review of the provisions made by the licensee for review and audit activities in,1 our review of the procedures for collection, evalua-tion and disseminr? ion of operating experience information, and subject to later verification of the adequacy of procedures EP-013 and AP-1032, we find that the licensee is making acceptable provisions for safety review and operational advice.
D.
TRAINING OF OPERATING STAFF Our conclusions regarding the training of the operating staff remain as stated in the Evaluation Report (pg. C5-7).
On August 8, 1980 the licensee submitted the Revised Licensed Operator Qualification and Requalification Training Program in response to our Mar:h 28, 1980 letter from H. R. Denton.
The review and approval of the Requalification Training Program is not required prior to any restart authorization since each of the licensed personnel at the facility will be required to successfully pass an NRC examination prior to resuming their licensed duties at the operating plant.
L
f,RC eom 335 U.S. NUCLEAR REGULATORY COMMISSION BIBLIOGRAPHIC DATA SHEET NUREG-0680, Supplement No. 2
- 4. T tlc AnO SusT TLE (Aaa vwume na.,reorcor,m; Tiil-l RESTART Subtitle:
- 2. u.,,a oi,*i Evaluation of Licensee's Compliance with the Short and Long Term Items of Section II of the NRC Order Dated August 9,1979, 3. RECIPIENT'S ACCESSION NO.
1etropolitan Edison Company, et al, Three Mile Island Nuclear
{
Station, Unit No.1, Docket 50-289.
- 5. OATE REPORT COMPLE TED MONTH l YEAR
[
March 1981 l
- 9. PERFORMING ORGANIZATION N AME AND MAILING ADORESS //nc/voe Zeo Code /
OATE REPORT ISSUED I
U. S. Nuclear Regulatory Comission eN T"ch lYEAR j
Office of Nuclear Reactor Regulation Mar 1981 1
Washington, D. C.
20555 6 It's
- a/*a*3 l
- 8. (Leave utanal
- 12. SPONSORING ORGANIZATION NAME AND MAILING ADORESS (inc,ioe 2,o Ccoei p
Same as 9 above.
- 11. CONT 9 ACT NO.
- 13. TYPE OF REPORT PE RLOG COVE RE O tinclus.ve dates)
Docket No. 50-289
- 15. SUPPLEMENTARY NOTES 14 It**ve * **l 1$. ABSTR ACT 200.vords or sess/
This supplement to NUREG-0680 (TMI-l Restart Evaluation) updates our review in the general area of management capability and resources and describes the resolution or status of unresolved items noted in Supplement I which was issued on November 28, 1980.
We conclude that the licensee has made substntial improvements in the area of management capability and resources a'nd that the licensee is in compliance with Item 6 of the August 9, 1979 Order as amplified by the March 6,1980 Order, except for one unresolved item.
- 17. KEY WOROS ANO DOCUMENT ANALYSIS 17a OESCRIPTORS s
17tt 40ENTIFIERSIOPEN ENDED TERMS
- 18. AV AILABILITY STATEM6NT
'h si e' No restrictions on distribution 2e SECURITY CLASS tra,,,,,e 22 PRICE N CC F Csau J35 4 7 77