ML20107G189

Notice of Issuance of Nuclear Safety & Compliance Committee 841023 Rept Re Observations Intended to Improve long-term Assurance & Maint.Related Correspondence

ML20107G189
Person / Time
Site:	Three Mile Island
Issue date:	11/06/1984
From:	Blake E GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
References
CON-#484-002, CON-#484-2 SP, NUDOCS 8411070251
Download: ML20107G189 (13)

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MLOGDCC'*;h.iCNDENCN CC}y TED Novembgg6"" g 1984.

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UNITED STATES OF AMERICA- '

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NUCLEAR REGULATORY COMMISSION BEFORE'THE ATOMIC SAFE'TY'AND LICENSING BOARD In the Matter of )

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289 SP

) (Restart-Management Remand) 3' (Three Mile Island Nuclear )

Station, Unit No. 1) )

NOTICE TO COMMISSION, APPEAL. BOARD LICENSING BOARD AND PARTIES In November, 1983, Mr. William G. Kuhns, Chairman of the Board of GPU, advised the Commission of plans to establish a Nuclear Safety and Compliance Committee (NSCC) of the GPU Nu-clear Board of Directors, composed entirely of outside members

! of the Board. In July, 1984, Licensee provided the Commission with a status report on the NSCC, which at the time was in

[ place and beginning to function with its staff.

The NSCC recently issued its first report which was dis-cussed with the GPU Nuclear Board of Directors on October 23, i 1984. The report and some related correspondence are enclosed.

The report includes observations intended to improve long term assurance and maintenance, and concludes that NSCC identified l

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no instances of non-compliance and that safety attitudes and

. practices are satisfactory.

Respectfully submitted, Su.4 C r%s,A. -

Ernest L. Blake, Jr., P.C.

Counsel for Licensee November 6, 1984 Enclosures cc: Service List s

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, TELEX 13e 4a2 Writer's Otroct Disl Number.

N;vemb;r 1,1984 (201) 263-6797 1

Mr. Harold Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Coeurission Mail Stop P-!?R c

, Washington, DC 20656 .

Dear Mr. Denton:

In his statement to the Consission on November 28, 1983, 1 Mr. Kuhns, Chairman of the Board of General Public Utilities Corporation,  ;

advised that the Board of Directors of GPU Nuclear Corporation was being restructured to have an outside Chairman and three other outside i

Directors. He also noted that these three outside Directors would 1 constitute a Nuclear Safety & Compliance Committee of the Board, which 4 would have an independent staff, and that the Committee's periodic reports

, to the Board would be furnished to the NRC and be made available to the <

i public. l

. My letter of June 29, 1984, provided a status on these matters l including the identity of the outside Directors and their staff.

l l The NSCC has provided their first report to the GPU Nuclear Corporation Board of Directors. Mr. O' Leary, Chaiman of the Board, has l requested that I provide it to you.

A copy of the report is enclosed. We are proceeding to serve it l l on the parties to the TM! 1 Restart Hearing.

Very truly yours, P. R. Clark President Pfk Enclosure cc: Chairman of the Board, GPUN - J. F. O' Leary shr.,, Pittman, Potts & Trowbridge - E. Blake, Esq.

l OPU Nue ev Carcer.st.:r .s s tes.cary cf Cer craA: . Jr.t.:u C reuse t.cn 1

Nuclear M Nisoleer i='a - o,o Co.opereden Perseparty,New Jersey o7C34114t.

(2o1)2e3 eSoo TELEX 13e 4a2 Writer's Direct Olal Number:

November 1,1984 (202) 363-2111 Mr. Philip R. Clark, President GPU Nuclear Corporation 100 Interpace Parkway -

Parsippany, NJ 07054 -

Dear Mr. Clark:

The initial report of the Nuclear Safety & Compliance Committee of the GPU Nuclear Corporation Board of Directors was forwarded to me by Mr. Laney's letter dated October 15, 1984.

Copies of the report were distributed to you and other members of the Board on October 17, 1984 and the report itself was discussed at the October 23, 1984 Board Meeting.

Confirming those discussions, you are requested to provide to the Board your response to the suggestions and reconnendations in the report.

This reply should be provided in time to allow the NSCC to review it and include in their next report to the Board an evaluation and status of your response.

In addition, you should proceed to provide this report and

subsequent reports to the NRC.

Very truly ours, J. F. O' Leary Chaiman of the Board pfk cc: Chaiman, HSCC - R. V. Laney Corporate Secretary, GPUN - W. B. Murray I

l GPU Stu; ear Cer: era:,c- s a sw:s.c ar, of GeneralD. ' c 'wtdit.es CP:7at.on 1

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1 Cetober 15, 1984 Mr. John F. O' Leary, Chairman

, GPU Nuclear Board of Directors 100 Interpece Parkway Parstypany, N. J. 07054 Dear Mr. O'Learyt -

The Nuclear Safety and Compliance Committee of the CPUN Nuclear Board of Directors transaits herewith its first semi-annual report, in i accordance with Section V of the Committee's Charter. We include

several observations intended to improve long tera assurance and i

asintenanea.

i The Committee identified no instances of non compliance. safety attitudes and practices are satisfactory. l 1

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Si oly R. V. Laney Chairman, NSCC RVLiek ces Board Members l

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l NUCLEAR SAFETY AND COMPLIANCE COMMITTEE REPORT NO. L

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GPU NUCLEAR SCARD OF DIRECTORS October 15, 1984 .

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R. V. Laney L. L. Humphreys V (/

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1 CONTENTS t,

I. SUMUutY .

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II. 19tI-i A. Root Causes of February 29, 1984 NRC Notice of Violation B. TMI-1/TMI-2InteractdonsinEmergency

Plans and Procedures C. Training i

j D. Operations I

! III. OYSTER CREEK ----

i i A. Operator Requalification Training i . Program I

, B. Operations i

C. Maintenance i

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SUMMARY

comunittee activities between the date of its formation, Februar phases.y 23, 1984, and the present were conducted la two

! During Phase I a staff was interviewed and hired through contract with the NUS Corporation, and a plan of activities was developed. A seven-man staff, reporting to the Cossaittee, Creek stations. is now functioning at the TMZ-1 and Cyster i

' In Phase %~I, beginning July 1, the Cosemittee be overviews of training, operations, and maintenance. gan specie,1 evaluations were conducted of events leading to the NRC's February 29, 1984 Notice of Violation at TNI-1; possible impact of THI-2 on TMI-1 under emergency conditions; and procedures for readiness to restart at TMI-1 and Oyster Creek. The results of these evaluations are discussed in this report.

In the course of its evaluations the Connaittee made several observations which are also reported herein for use by GPU Nuclear management.

The Consnittee and staff observed no non-compliances.

Safety attitudes and practices are satisfactory.

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II. THI-1 A. Root causes of February 29[_1984 NRC Notice of Violation at TMI=l_

The Cosunittee was interested in two technical specifica-tion violations related to maintaining containment integrity (1) a non-automatic containment isolation valve (IA-V20) was not closed; and (2) another*nen-automatic containment isola-tion valve (F5-V405) was not closed and the open-ended con-nection downstream was not capped. An earlier check of con-tainment integrity had erroneously indicated thene valves to be closed as required.

The March 30 response by GPU Nuclear to the Notice of Violation attributes the valve problems to personnel error.

I Neither the operator nor the engineer who checked valve IA-V20 recognized that the backed-out stem bushing nut was

. blocking complete closure. In the case of FS-V405, the op-erator did not properly reclose the valve and install its cap following local leak rate testing.

The committee agrees with management's finding of per-sonnel error. The committee.also agrees with the remedial actions, including increased emphasis on procedure adher-ence and changes in the containment Integrity Checklist to require an examination for obstructions that could prevent full closure. We note that, after the problem was discovered, twenty days passed before repairs to IA-V20 were completed.

This time appears too long; the Committee therefore recem-i mends a review of repair priorities used for safety related components.

Despite the failures noted above, in each case a second-l ary boundary valve was closed and no actual physical violation of containment occurred.

a. TMI-1/TMI-2 Interactions in Emergency Plans and Procedures The Committee conducted an overview of TMI-1/T:tI-2 in-teractions to deter.nine if emergency plans and procedures adequately provide for the safety of Unit 1 in the evant of l

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lo l an incident at Unit 2, and to review physical interties be- i tween Unit 1 and Unit 2 to deterruine if any of them might pose a threat to Unit 1.

The Conamittee finds that Emergency Plans and Procedures are adequate for handling emergencies within each unit's i domain. Numerous emergency exercises have demonstrated that the procedures of each unit are understood and implemented.

i The Committee notas that the Unit 1 Control Room is desig-

, nated as the backup Technical Support Center for Unit 2.

We believe that this designation is questionable and should be reviewed by management, ,

A review of physical interties between Unit I and Unit 2 reveals that there are several liquid radwaste valves .

which must be maintained closed in order to assure plant-to-plant separation. Surveillance procedures for verifying these valve positions -- visual check for pulled fuses and disconnection of actuating air lines -- are inconclusive in that they do not confirm actual valve positions. The committee concludes that the valve designs preclude obtain-ing positive assurance of valve closure. We therefore recom-mend that management consider some means of positive separa-tion, for instance by blank flanges or removable spool pieces.

C. TMI-1 Training i During the week of September 10, 1984, the Committee

staff conducted an overview of TMI-l operator training pro-i grams, including simulator activities. The. programs were >

! found to be competent and thorough. There were no observa-tions of safety significance. Training evaluation continues, with focus on safety and compliance.

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D. TMI-l Operations l l

The' Committee's operations overview concentrated on assessment of safety attitudes and procedure compliance in operations and on readiness for researc. Initial observa-tions indicate that the operations staff conducts itself in

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. a professional manner and shows a positive attitude toward safe operation and adherence to procedures. Daily planning meetings were observed to be brief and efficiently con-ducted. Excellent plant cleanliness is another positive indicator of a sound operating approach.

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The comunittee staff evaluated the TMI-1 Readiness to Restart Program, focusing on adequacy of program coverage and the pro =ess of execution. No safety or compliance is-suas were identified. The process provides reasonable assurance that prerequisites will be identified and com-plated. -

The Committee believes that preparations for restart

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operations evaluation continues with particular atten-tion to safety and compliance.

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i III. OYSTER CREEN A. oyster creek operator Reaualification_Trainine Prooram The comunittee and its staff conducted an overview of the licensed operator requalification program to assess improvements being made. We note that both issnediate and

long-term action plans are underway to strengthen the re-qualification program. The inunadiate need has been met by implementing an Accelerated Reit ualification Program, reexam-4 .

ination, and oral boards for those individuals who had prob-less on earlier requalification examinations. These offorts have been successful in all applicable cases. '

There is a connaitment to provide training review matar-

. ial on plant systama, procedures, nuclear theory, thermal i hydraulics, heat transfer, and fluid flow for future requal-l ification programs. Requalification training of all licensed reactor operaters has been raised to the highest priority by viant operations.

i The conunittee and its staff observed no items of non-compliance or safety significance.

The connaittee notes that the current five shift rota-tion makes it difficult to complete all training require-i ments. We endorse the management's plan to implement six i shift rotation.

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l B. OJster creek Operations 1'

The comarittee and its staff have made a preliminary l assessment of compliance with safety procedures and safety attitudes in the oper**lons Department, and have evaluated the Rectart Certification Program.

Adherence to safety procedures by operators is observed to be satisfactory. Knowledge and ' professionalism are evid-ant. No non-compliances or safety related observations were miade .

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9 The Restart certification program is comprehensive in of plant operation which are related to restart. scope, with a ship of the Restart Readiness Comunittee includes The membe !i, all essen r-tial areas of management and technical expertise, l

! and compliance. operations evaluatics continues with focus on safety C. Oyster Creek Maintenance .

The commalttee and its staff have made a preliminary overview of maintenance activities. No found no non-compliances and have no safety related observations.

In the course of this review we find that the present i Important to safety (ITS) List, which designates ITS sys-tems without further breakdown, is inadequate to support efficient maintenance activities. Its uce may lead to in-4 i

consistent or incorrect classifications. The Cossaittee

! endorses present activities to prepara and implement a component level ITS data base plan for cyster Creek and ,

TMI-1 , l Review of procedures concerning post maintenance test--

ing indicates that they do not consistently specify if a test is or'is not requ;, red after maintenance. As a conse- '

quence, the decision to test is left to the discretion of i -

the supervisor after maintenance is completed. It is sug-gested that Oyster Creek management review this matter.

Maintenance overview for safety and compliance continues, I

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