ML20082Q757

Provides Status of Actions Taken Since Followup SALP Review Meeting on 920924

ML20082Q757
Person / Time
Site:	Crane
Issue date:	07/02/1993
From:	Phyllis Clark GENERAL PUBLIC UTILITIES CORP.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
C311-93-2043, NUDOCS 9505010078
Download: ML20082Q757 (13)

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GPU Nuclear Corporation N

IG8r One Upper Pond Road Parsippany, New Jersey 07054 201-316-7000 TELEX 136-482 Writers Direct Dial Nurnbet (201) 316-7797 July 2, 1993 C311-93-2043 l

I Mr. Thomas T. Martin Region I, Regional Administrator U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

Subject:

Three Mile Island Nuclear Station, Unit 1 (TMI-1)

Operating License No. DPR-50 Docket No. 50-289 Systematic Assessment of Licensee Performance (SALP)

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1993 GPU Nuclear Status Report for THI-1

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Reference:

(1) NRC letter dated March 23, 1992, T. T. Martin to T. G.

Broughton, " Systematic Assessmer.c of Licensee Performance (SALP) Final Report Number 50-289/90-99 i

(2) NRC Inspection Report Number LO-289/92-18 dated j

November 12, 1992 The purpose of this letter is to provide the status of actions taken since the Followup SALP Review Meeting at the NRC Region I offices on September 24, 1992.

The last SALP report is contained in Reference 1 and a review of the Followup SALP Meeting is contained in Reference 2.

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GPU Nuclear viewed the Followup SALP Review Meeting as a beneficial exchange of information. There is no need to restate the issues addressed in that review.

Accordingly, Attachment 1 provides the status of the actions taken since that meeting and other issues not previously covered. We hope this information is i

helpful to your staff in developing a current status and overall evaluation of THI-1 performance.

goto lfj GPU Nuclear Corporation is a subsidiary of General Public Utilities Corporation

t T. T. Martin C311-93-2043 Page Two i,

GPU Nuclear remains committed to continued improvement of performance in all i

areas. We judge the actions taken or underway as reported herein, to be consistent with that objective and reflective of management's commitment to achieving improved performance. We look forward to a constructive dialogue J

following receipt of the SALP report.

l Sincerely, P. R. Clark President DVH/mkk 2

Attachments 4

t cc: Document Control Desk E. W. Hernan - TMI-1 Senior Project Manager M. G. Evans - TMI Senior Resident Inspector l

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GPU NUCLEAR i

THREE MILE ISLAND UNIT 1 4

i UPDATE ON SALP STATUS 4

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• :i T. T. Martin Attachment C311-93-2043 Page 1 GENERAL OVERVIEW e

The rerack project to the TMI-1 Spent' Fuel Pool was completed. A number of racks in the "A" Spent Fuel Pool were modified to allow storage of more fuel assemblies in that pool for full core offloads -through the end of Cycle 14 (year 2001).

e The total occupational dose for 1992 at TMI-1 was 33.9 person-rem as

' his is the lowest. exposure year in compared to a goal of 45 person-rem.

t the history of the plant. 'This notewort.hy accomplishment is the result of the ALARA program which continues to be effectively implemented at TMI.

Continued piogress has been made in procedure improvements for i

maintenance, infrequently performed operations, and operations surveillances. The Maintenance Procedure Upgrade Program was initiated in 1989. This nro9 tam provided formal training in procedure writing for those involved including a number of bargaining unit employees. This provided not only immediate improvement in the quality of procedures but also longer term improvement through better knowledge in the workforce of procedure quality. This program has progressed to the point where QA no longer performs in-line review of the maintenance procedures but rather is transitioning to a performance based overview. The Maintenance Procedure Upgrade Program has been completed and has resulted in significant improvement in the level of detail and quality of maintenance procedures.

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Based on reviews of past occurrences, particularly those which occurred during the 9R Outage, TMI-1 management determined that some infrequently performed evolutions had resulted in a high error rate and undesirable i

consequences. A review of procedures for those evolutions indicated opportunities for improvements, primarily in clarity and useability, as well as technical content. TMI-1 management determined that the procedures in this category should receive a special review, on a one-time basis, by teams of representatives having expertise in different areas.

Although initial planned corrective action was expected to be complete in the first quarter of 1993, 29 of 38 total procedures have been revised, with the remainder of the procedures to be completed by the end of July 1993. No major. technical problems have been identified. The overall effect of these improvements are procedures which are significantly improved from human factors perspectives and useability point-of-view.

Operations surveillance documents have been reviewed on two separate occasions in this SALP period as a result of two separate, unrelated j

incidents. Both reviews have resulted in improved documents with the i

1 result of several operations surveillances being incorporated into existing procedures.

e T. T. Martin Attachment C311-93-2043 Page 2 The improvements in procedures have focused on revising procedure steps which have been known to create problems. These steps are revised which results. in procedures with less potential for problems.

In summary, there has been and continues to be management attention to the content, quality and use of procedures.

On February 7,1993 TMI-l declared a Site Area Emergency due to a vehicular intrusion of the Protected Area. The event of February 7, 1993 resulted in no adverse effect on the health and safety of the public.

Actual plant consequences consisted of significant damage to the Protected Area Gate #1 and the Turbine Building roll-up door. Minor damage to a condensate polishing resin liner and a few Auxiliary Boiler components also resulted.

GPUN has had several-internal groups reviewing this incident and the NRC commissioned an Incident Investigation Team (IIT) review of the incident, as well as followup regional inspections. The IIT issued a report and briefed the NRC Commission on April 6, 1993. The Region I inspection reports have not yet been issued. This incident continues to receive a high level of management attention; therefore, it is not addressed further in this presentation.

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FUNCTIONAL AREA:

OPERATIONS OUTAGE MANAGEMENT i

i TMI-1 is preparing for the 10R Refueling Outage which is scheduled to start on September 10, 1993.

In this SALP period TMI-1 has not had a scheduled refueling outage. As a result of lessons learned from the 9R outage and the i

last SALP report, GPUN has made a number of improvements. Among these are:

e The progress in upgrading infrequently performed procedures, as described above, will be evaluated during and after the 10R outage, e

Training seminars for Operations Foreman and Supervisory level personnel were conducted in the last part of 1992. This training included the review of previous events, proper preparation for performing an evolution (e.g., job planing), and monitoring of events and the effect on the plant.

Preparation for planning the 10R outage is proceeding on schedule. GPUN plans to conduct an outage briefing for the NRC Region I staff on July 21, 1993.

GPUN continues to view these briefings as mutually beneficial.

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C311-93-2043 i

Page 3 OPERATOR CHALLENGES i

During the SALP period, the challenges to operators has been infrequent, j

However, for those few challenges, the operators' response has been proper and j

prompt. Twc specific examples are the response to a grid transient in June i

1992 and the failure of a seal injection flow control valve to control in automatic in May 1993.

In both instances, the plant was operating at 100%

i power. The operator response stabilized the plant and returned the plant to i

full automatic control.

HUMAN PERFORMANCE i

i The BE E RE (Stop, Understand, Respond and Evaluate) program implemented June 30, 1992, is being reinforced. This-is a self-checking program intended for use by each individual involved in plant activities.

Event review and 4

analysis has been improved by providing additional members formal training in i

the Human Performance Enhancement. System techniques and through the expanded i

use of the Plant Experience Report Program (described in Section 3D'herein).

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GPUN intends to continue this program to assist in reducing operational events.

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i 0PERATIONAL IMPROVEMENTS Fouling of the condenser due to asiatic clams appears to be resolved. There l

were power reductions to perform cleaning of the condenser in the second half 1

of 1992 and again in March 1993.

In addition to cleaning the condenser, silt was removed from the cooling tower basins in 1992. TMI is continuing periodic 4

chemical additions to preclude clam propagation and reoccurrence of the fouling g

problem.

Indications are the chemical treatment of the river water system is effective. GPUN will continue to monitor and evaluate this program, i

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OPERATOR EXAM RESULTS j

During this SALP period the NRC administered a requalification examination to one TMI operating crew and two staff crews; all three crews and 15 of 15 i

individuals passed. The remaining operators not examined by the NRC have passed the GPUN-administered biennial examinations. On two separate occasions the NRC administered initial examinations. Of a total of four operators who j

participated, all passed on the first attempt. No programmatic weaknesses were i

identified.

i In July 1992 the NRC conducted an audit of the effectiveness of the operator i

training programs and found them to be fully responsive to the needs of the j

plant.

j INPO accreditation renewal of the operator and shift technical advisor training I

and qualification programs was successfully achieved in February 1993. The j

programs evaluated were for non-licensed operators, control room operators, senior reactor operators, shift supervisors, continuing /requalification of j

licensed personnel, and shift technical advisors.

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FUNCTIONAL AREA:

MAINTENANCE i

INPROVED PLANT NATERIEL CONDITION SINCE LAST SALP The plant materiel condition continues to improve. This is evidenced by fewer equipment problems and the small amount of rework required. The_ maintenance backlog of work is being controlled and is maintained at a reasonable level.

l Specifically, there are several programs which are contributing to the overall betterment of the mate-iel condition. Among these are:

e Valve Packing and Valve Replacoment Program - This program is showing visible positive results and is nearing completion.

Plant Preservation Program - This program, ongoing for several years, is manifested in improvements in the lighting levels and in the plant appearance. _ Preparation activities have revealed minor material i

deficiencies which had gone unnoticed.

Thermography and Vibration Analysis - These are maintenance diagnostic techniques used to assist in early detection of equipment problems.

Examples are:

The Plant implemented a phased-in (over the course of several outages) installation of an improved main turbine vibration detection system. The installation is coordinated with the disassembly of the turbine sections intended for overhaul. This significantly reduces the cost of installing the detection system.

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The plant installed a computer-based loose parts and vibration l

monitor. This data can be transmitted to remote locations for prompt analysis in the event of an alarm.

i Thermography has located high temperature connections in electrical circuits supplying control rods and vital busses. These connections were located prior to any adverse impact on the plant.

NAINTENANCE TECHNICIAN TRAINING The maintenance training.was significantly enhanced by the addition of four classrooms and a mockup storage building, and by conducting the majority of maintenance training in a hands-on environment in the workshops / laboratories, using plant-specific equipment where appropriate. The qualification training for TMI-2 Electrical, Mechanical, and Instrumentation & Controls personnel who are to be transferred to TMI-1 has been completed.

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C311-93-2043 i

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FUNCTIONAL AREA:

PLANT SUPPORT i

A.

RADIOLOGICAL CONTROLS As noted in the General Overview, the TMI ALARA Program has been successful in reducing total radiation dose to a very low level.

There were 11 skin contamination incidents at TMI-1 in 1992. Two of these were l

>10 mrem. The highest dose was due to a hot particle and the dose to the skin of the hand was estimated at 73 mrem.

There were 51 clothing contaminations at TMI-1. The majority of these were in areas in the Auxiliary and Fuel Handling Buildings. Steps were taken to i

minimize their occurrence in the future.

The major rerack of the Spent Fuel Pool at TMI-1 was performed without a major radiological incident. There were 48 dives associated with rerack and radiological controls were effective throughout this potentially dose intensive task. The total dose was 5.8 person-rem versus an estimate of.6 person-rem.

TMI-1 has identified an area for improvement concerning station personnel performance in radiologically controlled areas.

Senior plant management has reinforced the need for sustained adherence to Radiological Controls standards at Management Interface meetings and through the Management Off-Shift Tour Program.

In addition, health physics problems are being discussed with the workforce at periodic plant, shop, and shift meetings. Evaluation of the effectiveness of these actions is ongoing.

Reduced micron size filters in the primary system have ef.fectively minimized insoluble crud buildup in plant piping (i.e., hot spots) during the operational cycle.

Two Radiological Engineers achieved Certification by the American Board of Health Physicists.

There were only two Radiological Investigative Reports in 1992 at.TMI-1. This is the lowest number since this program was inplemented..0ne involved a problem with Source Accountability. Additiont.1 problems with the source accountability program has prompted a specia! QA audit to identify weaknesses and determine actions to strengthen the program.

Rad Engineering coordinated the consolidation of TMI-1 and TMI-2 REMP Programs in the ODCM to effect a more efficient program (i.e., one set of site standards).

Management changes within the Rad Con organization include the assignment of William E. Potts as the Rad Con Director, TMI, effective April 1, 1993; and a change in the Manager, Rad Con Field Operations from Donald E. Tuttle to Peter Velez, effective May 1, 1992.

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. T. T. Martin Attachment C311-93-2043 l

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EMERGENCY PREPAREDNESS i

l In 1992, additional duty roster positions were added and staffed resulting in a l

four-section rotation for many Initial Response Duty Roster members. As a i

result, there are more qualified, trained personnel available to respond to an emergency.

In addition, a new position, EOF Information Coordinator, has been J

added to the Emergency Support Organization duty roster to enhance the flow of technical information at the facility.

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i Special amplifiers were placed in the dedicated Notification Line telephones in the risk counties and PEMA to improve the signal quality under conditions when 4

more than one line is active at those offsite agencies. The improvements have helped to prevent the problems experienced during the 1991 TMI exercise in 3

j which one county did not get the full protective action recommendation from 3

PEMA due to low telephone line volume.

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A backup Remote Assembly Area (RAA) was changed in 1992 from a rented facility I

to a facility owned by GPUN. As a result, personnel monitoring equipment has i

been permanently stored at the RAA as op>osed to moving the equipment to the

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facilities at the time of an incident; tius, improving our readiness to respond 1

to an incident.

A microwave link was established with PEMA providing an additional means of communications should the telephone company's main switching station in i

Harrisburg fail.

j A variable trajectory Class 8 dispersion model (MIDAS) was implemented, enhancing the ability to correlate field team data acquired during an emergency.

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with dose projections calculated by the RAC.

Revision 6 of the Emergency Plan was approved by the NRC in 1992. The most i

significant change was the incorporation of mode applicability (plant l

conditions) into the EAL's.

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General Emergency shift drills were conducted for the operating shifts in 1992 j

as part of Operator Training to give the Shift Supervisor Emergency Directors more experience in classifying a General Emergency and determining Protection j

Action Recommendations.

The full-day training session conducted by GPUN for all of the TMI offsite i

emergency. workers has increased in popularity over the last several years.

j Attendance was significantly higher in 1993 (220 vs. 161), and it has more than doubled over the last two years.

It should be noted that this session is in addition to the training sessions conducted at the individual municipalities throughout the year.

GPUN is currently working with the TMI risk municipalities in' revising their plans and conducting training to incorporate Pennsylvania's new dosimetry policy. TMI municipalities were the first in Pennsylvania to be evaluated against this new policy during the May 19, 1993 annual full participation TMI exercise.

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T. T. Martin Attachment C311-93-2043 Page 7 i

C.

SECURITY SALS t.CCESS LOGGING SYSTEM SALS, a Site Access Logging System, was put into operation at the North Gate in 1992. This is a computer-based logging system for control of'all visitors and permanently badged personnel entering TMI. As employees enter and leave the site, their badge number is entered on a numeric keypad or data logger which communicates with the SALS computer based onsite in the Processing Center. The information captured by the data loggers is stored magnetically on a hard disk for future retrieval.

The data gathered by the SALS is easily retrievable through a series of report generators. Some of the reports include Personnel Currently Onsite, Ingress / Egress Activity of any/all personnel, and Visitor History.

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SECONDARY ALARM STATION The entire alarm station was remodeled. The changes resulted in a less j

strenuous operating atmosphere and a more efficient operatit.n.

I State of the art video switching equipment was installed to provide for l

improved surveillance of the Protected area.

Existing security computer i

equipment was repositioned for ease of operation. These changes placed all equipment required by the operator to perform his/her duties in close proximity to the operator.

The gate opening procedure has been changed to make use of software options in the Security system whereby a manually operated opening device was replaced with an electronically activated system. This system not only controls the activity of the gate, but also logs to a historical file all activity at the gate to include the name(s) of personnel opening / closing the gate.

PERIM ALERT SYSTEM V The new System V has been installed and provides significant benefits over l

previous Perim Alert II system.

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l TACTICAL ~ TRAINING:

l In November 1992, four Site Protection Officers were' enrolled in a course in f

Tactical team Operations I Training at The Institute of Public Service.in.

Gainesville, Georgia. This was a week long course that covered tactics that -

can be used by TMI in Security training and included: Building Clearing, 1

1 Clearing Fundamentals, Fatal Funnel, Door Entries, Team Movement, Tactical j

Firearms Training, Repelling Fundamentals, Reduced Light Firearms, and Stress 4

Course Firing.

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SAFETY ASSESSMENT / QUALITY VERIFICATION e

The Safety Issues Assessment Process (SIAP) review group consists of senior managers from the TMI-1, Technical Functions, and Corporate Services divisions and is coordinated by the Independent Safety Review (ISR)

J department. The issues evaluated by this group include generic industry issues.as well as TMI-specific issues. The group has met several times since the last SALP to evaluate issues on the basis of potential to enhance nuclear safety.

l The following identifies the major quality assurance and verification j

improvements or challenges since the last report.

STRENGTHS 1.

Quality Verification l

The number of open, long-term deficiencies remains low. Response to i

Quality Assurance identified items continues to assure resolution of 3

l concerns in a timely fashion.

Plant requests for Quality Assurance support have continued in various activities, including switching and tagging, TSI firewatches, and j

drawing control.

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Performance-based observations program and techniques have been i

implemented. Observation of activities included overview beyond i-compliance and expectations of management are considered when i

reviewing results.

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Engineering The Mixed Bin Walkdown Program and Bill of Material projects underway will provide an increased assurance of accurate spare parts status and i

enhancements to material and component computer data bases.

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To T. Martin Attachment C311-93-2043 l

Page 9 CHALLENGES 1.

Engineering Support The QCL engineering data base requires upgrade.

The review for accuracy and completeness of this data base is ongoing and should continue to receive attention.

In January 1992 the Plant Experience Report-(PER) program was initiated.

This program combined the previous Plant Incident Reports and multi-discipline review of Level II Log entries. The PER Program satisfies all the requirements of 10 CFR 50 Appendix B and the GPUN OQA Plan for a corrective action system.

The PER has resulted in the Plant Review Group (PRG) having a bigger role in reviewing, assigning responsibilities, and follow-up.

Second, trending of less significant events (Threshold Events, NPDES reports, Surveillance Deficiency Reports, and Maintenance History Assessments) can result in

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initiation of a PER if these lesser events show a significant adverse trend which would require a broader corrective action.

The PER Program has existed for a year and a half and has developed into a valuable part of event analysis.

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LICENSING ACTIVITIES l

Technical Specification Change Requests for primary-to-secondary leakrate l

limits and reactor coolant pump snubber operability requirements were submitted for NRC approval well in advance of the potential relief date. The technical i

justification supported the proposed relief and early submittals for relief avoided an unnecessary plant shutdown or expenditure of resources by GPUN and the NRC due to a possible exigent relief request.

4. FUNCTIONAL AREA:

ENGINEERING 1.

A System Engineering Section was added at the site and fully staffed in 1992. System Performance Teams were formed with representatives from Engineering, Operations, and Maintenance.

Each~ team held at least one meeting by the first Quarter of 1993 and the members are now developing long term systems plans.

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The plant implemented the Feedwater Flow Correction Factor Program to compensate for the fouling on the Main Feedwater Flow Nozzles. A factor is utilized which enables the plant to reach its rated thermal power. This program approach was discussed with the NRC Staff at a meeting in Rockville; by teleconference with staff in Region I (King of Prussia); and, most recently, with Region I personnel onsite.

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T. T. Martin Attachment C311-93-2043 Page 10 3.

Primary Chemistry Laboratory sample panel was redesigned to make permanent the Hydrogen Analyzer and the Gas Stripping Rig and to reduce exposure by making the valves more maintainable and accessible.

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Potential sources of contamination in the Auxiliary Building were reduced by eliminating temporary tygon hose run. The floor was trenched and permanent underfloor drain tubing was installed; the trenches were re-grouted.

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Engineering provided support to eliminate the potential source of cross-contamination between Unit 1 and Unit 2.

The source has been identified as a cross-connection from the Unit 2 to the Unit 1 Aux Boiler piping, i

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The Configuration Reconstitution effort continues to make steady progress as Design Basis Documents (DBD) are prepared. During this period DBDs were completed on the following systems.

l Reactor Building Spray Low Pressure Injection / Decay heat Removal Main Feedwater/ Condensate High Pressure Injection / Makeup Extraction Steam Instrument Air The Program continues to recover key design basis information and documents them in an easily retrievable location. The documents are being placed on a data base available to all employees and a program has also commenced to place all references on a data base through an imaging recovery program.

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A Safety System Functional Inspection (SSFI) was completed on the Low Pressure Injection System (LPI) during this SALP period. This is part of a continuing program, started in 1988, to perform a self-assessment of systems to determine if a system is operated and maintained consistent with its design basis.

This is a " vertical cut" through a system similar to SSFIs performed by the NRC. An experienced, independent outside organization completed the inspection which was supported by GPUN personnel. The challenging review found no safety significant deficiencies.

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