ML20117N065

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Forwards SALP Input for Oct 1982 - Jan 1984
ML20117N065
Person / Time
Site: 05000000, Crane
Issue date: 03/29/1984
From: Ronald Bellamy
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Keimig R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20114G054 List:
References
FOIA-84-616 NUDOCS 8505170372
Download: ML20117N065 (3)


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UNITED STATES NUCLEAR REGULATORY COMMISSION

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,c KING OF PRUSSIA, PENNSYLVANI A 19406 M?R 29 igy MEf;0RAtiDUM FOR:

Richard R. Keimi g, Chie f, Project Eranch No. 3, DPRP FROM:

Ronald R. Bellamy, Chief, Radiological Protection Branch SUEJECi:

iHREE MILE ISLAliD UtilT 1 SALP Attached for your infomation is the SALP input. for TMI Unit 1 (SALP period October 1,1982 to January 31,1984).

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Ronald R. Bellamy, Chief K Radiological Protection Branch Attactment:

As stated D

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a THREE MILE ISLAND UNIT 1-SALP 6!

LEmercency-Preparedness An emergency preparedness inspection (50-289/82-25) was conducted on 1 November-4-9,-1982, tc evaluate corrective actions regarding seven items requiring resolution anc eight improvement items which had been identified-during the emergency preparedness a;praisal (50-289/81-20) on July 13-24, 1981.

As a result, four items receiring resolution (Appendix A items) and all improvement items (Appendix B items) were closed. One of the remaining Appendix A items pertain to modifications of the reactor building _eyacuation alarm and the other two pertain to installation, calibration and procedures for post-accident sampling.

During the November 1982 inspection, the evacuation alarm system was noted as being modified, but-performed poorly when tested on November 5-12, 1982.'

Another-inspection (50-289/83-13) was conducted on May 9-11 and June 29, 1983, to verify completion of-the three items that had remained open and to_ ascertain whether corrective actions regarding deficiencies identified during the emergency exercise (50-289/82-12) conducted on August 11, 1982, had been implemented. The inspectors verified that the three

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Appendix A items were closed.

It is noted that the reactor building alarm. system had been modified 'and acceptably tested.

In addition, the inspectors closed.TMI-1 Restart Certification Items 137A and 137B, which are concerned with training of local offsite support groups (e.g.

-ambulance; service, state police)..The inspectors noted that licensee's ccmmittments, in a letter dated January 13, 1983 (5211-83-012) to the NRC, pertaining'to exercise findings were being actively pursued, bL. tiad

. net been ccmpleted.

These items included a new-Emergency Operations Facility (E0E) and significant mcdifications to their Technical Support (TSC) and 0;eratienal'5u; pert Certers (CSC).

Other exercise findines which required re-training of cbservers and exercise participants had been ccmpleted.

On' November 3-4, 1983, a special inspection (5C-289/83-31) of the licensee's Prompt Nctification Systems was conducted.

As a result, the inspector verified that ade.ir.istrative arc physical means-to alert and provide prcmp: instructions tc the puolic within the Emercency Planning Zone' (EPZ) were in piace.

A full scale exercise inspection (50-289/83-25) was conducted on November 15-18,.1983.

As a result of the exercise, the inspectors concluded that within the limitations of the exercise scenario the licensee's emergency k

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Three Mile Island Unit 1 SALP 2

response provided adequate protection of public health and safety.

In acdition, the licensee's emergency response organization demonstrated acceptable implementation of their Emergency Plan and Emergency Implementing Procedures.

Acditionally, the inspectors notec that Emergency Response Facilities (e.g. OSC, TSC and EOF) showed marked improvement over the previous exercise.

New and upgraded facilities (including a new building for the EOF) and equipment contributed to a coherent and overall very good accident res'ponse.

The licensee has been responsise to NRC initiatives and acceptable resolutions were proposed and implemented on a timely basis.

Summary-of-Ratine Category 1 i

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NUCLEAR REGULATORY COMMISSION a-A.",. l.d '-

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~-af April 4,1984 Docket No. 50-289' MEMORANDUM FOR:

E. Conner, Chief, Reactor Projects Section No. = 35, PB No. 3, Region I FROM:

James Van Vliet, Project Manager Operating Reactors' Branch i4, DL

SUBJECT:

NRR SALP INPUT FOR TMI-l Enclos)d is NRR's SALP input for TMI-l for the period 10/1/82 through 1/31/84.

This input has been prepared in accordance with I.

NRC Manual Chapter 0516 criteria.

James Van Vliet, Project Manager Operating Reactors Branch #4, DL Enc 1osure:

As Stated cc:

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NUCLEAR REGULATORY COMMISSION

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.....s Facility Name:

Three Mile Island, Unit No. 1 Licensee:

GPU Nuclear Corporation NRR Project Manager:

James A. Van Vliet I.

Introduc' tion This report-presents the results of an evaluation of the licensee, GPU Nuclear Corporation in the functional area of licensing activities.

It -is intended to provide NRR's input to the SALP review process as described in NRC Manual. Chapter 0516.

The review-covers the period 10/1/82 to 1/31/84.

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.The basic approach used for this evaluation was to first select a number of licensing issues which involved a significant amount of staff manpower.

Comments were then solicited from the staff.

In most cases the staff-applied the evaluation criteria for the perform-ance attributes based on their experience with the licensee or its products.

Finally, this information was assembled in a matrix which allowed an overall evaluation' of the licensee's performance.

This evaluation is based on staff input from branches in three NRR divisinns.

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'II.

Summary of Results NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a performance category based on'a composite of a number of attributes.

The single final rating is then tempered with judgenent as to the significance of the individual elements.

Based on this approach, the performance of GPU Nuclear Corporation in the functional area - Licensing Activities - is rated category 2.

III.

Criteria

. Evaluation criteria, as civen in NRC Manual Chapter Appendix 0516 Table 1.

were used for this evaluation.

IPerformance Analvsis IV.

The licensee's. performance evaluation is based on a consideration of seven attribut'es as given in the NRC Manual Chapter.

For most of the licensing actions considered in this eveluation, cnly three or four of the attributes were of significance.

Therefore, the composite rating is heavily. based on the following attributes:

- Manacement involvement

- Appr5ach tr resolution of technical issues

- Responsivene;s 6

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!Of the remaining attributes of:

- Enforcement History

- Reportable Events

- Staffino

- Training only: staffing was judged to apply to the licensing activities evaluated.

The evaluation was based on our evaluation of the followino licensino

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activities:

- Respcnse to NUREG-0737 Items

- F. ire Protection Program ( Appendix R

. Requirements)

- Steam Generator Recovery Program s

- Pre-Restart License Amendments

- Seismic Qualification of Auxiliary Feedwater

- Licensed Operator Requalification Program Changes

- Inadequate Core' Cooling Instrumentation

- Plans for Preventing Exceeding PTS Screening Criterion

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- Long Term Review of Containment Purge.& Vent

- Effluent Discharge Monitor Relocation

- Raising HPI &,LPI Bypass Setpoints

-Station Distribution Voltage Verification Test

- Post-Accident Shieldino Alternate

- Environmental Qualificition A.

Managenent involvement in Assurino Ouality

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Over'all rating for th'is attribute is category 2.

Ali rated activities were censidered category 2, except for the steam generator recovery progren and the effluent discharge monitor relocatien which were

' rated categcry 1 and the envircnmental qualification program which was. rated cate; cry 3.

In ceneral, the level of renagement involve-ent has been apprcpriate for the significance of the issue.

Prior planning, prioritization of activities and corporate management inv'o.1ve-ment in site activities are evident.

In the case of the steam generator recovery program, an issue of high company priority, safety significance, and public visibility, involvement by the highest levels of GPU '

management'has been readily apparent.

The effluent discharge monitor relocation licensing activities seemed to have been well founded and-preperly presented, thus implying close management involvement.

There is, however, little indication of management involve ent in the TMI-i cr.virer. mental cualification issue.

This ccnclusien was eachec' :Esec. r-eview cf i.um er cf e c' :- e tai cuaiMicz-ion

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,submittals, and o.ne meeting 'on this subject with GPU Nuclear personnel.

Subsequent to'the evaluation period, another meeting ahd a two-day saudittof the environmental qualification files were co'nducted: and the results confirm our' conclusion'in this report.

There is little evidence of programmatic planning for the TMI-1 environmental quali-fication program.

The. Corporate. Policy on environmental qualification-became; effective.on January 20_,-1984 and it is not clear what the previous policy may have been..-There is no indication of any management;or cuality assurance review of the environmental qualification files. - Although-the files generally seem to contain the information needed to demonstrate cualification_, there is no GPU analysis, cther than miscellaneous hand-written notes, describing how the information relates to TMI-1 and why it demonstrates qualification.. There is no

-indication'that environmental qualification decision making is being done~at the appropriate management level.

More management

attention is needed.

B.

Aceroach to Resolution of Technical Issues from a Safety Standooint i

'Overall. rating for this attribute, is category 2.

Six issues were

' rated category 1 and eight issues were rated category 2.

There were no. category 3 ratings.

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'The~ licensee's understanding of the issues.has been. generally apparent and.the proposed resolutions have been generally conservative and

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sound.

In particular the licensee's approach to resolution cf fire protection'. (Appendix R requirements) demonstrates a clear urderstanding of, the-technical i-ssues; leading to technically sound, thorough approaches for resolution of the issues..The. licensee's steam

' generator' recovery program has continued to be thorough, well planned,. conservative and technically sound.

For_both of these

' issues,'the licensee has frecuently, posed ouestions and requestcd ciarifications from the staff en technical or licensing aspects of th Eissues.

-This has tended to assure centinued clarity of the issues tc be resolvec and ci'r.imized false starts, rework, etc.

For-

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. environmental cualification, the catecory 2 rating is cargiral, but in; rove ent is anticipated as a result of increased management involvement (see above).

C.

b.escensiveness to MEC-Initiatives

'Overall rtting:for this attribute is category 2, with all activities rated category 2.

A noted trend is that the licensee is most responsive to those issues tnat licensee considers having hicher priority (those issues impacting restart).

Issues to which ficensee assigns lesser triorities.;eriodically recuire submittal schecule extension..Aithcugh it is not an activity listed in the evaluation

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matrix, the Centr,cl cf Heavy Leads is one issue for which sicnif.icant subr.i-tal extensiens have-beer. necessary.

Licensee resocnses te NEC-initiatives ere cenereilv stenc and incrougn; ard asce**af e'resciutions are gebe"all; h* ::sec, P

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Enforcement Historv

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Re:ortinc and-Analvsis:of-Reoortable Events flot" appli cabl e.

F.

Staffino:(Includino Manaaement)

Staffing was only evaluated for two activities, thus there is

' insufficient basis for a meaningful overall rating of this attribute.

Staffing was rated category 1 for the steam generator

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recovery program.

Consistent with the scope and priority of the steam generator recovery program, the licensee has dedicated ample staffing.(including management) of appropriate cualifications.

Staffing was rated category 3 for environmental cualification.

Two : engineers are currently assigned to TMI-1 environmental qualification.

This level of staffing is significantly smaller than the leveis seen at other utilities.

It therefore appears that additional staffing would be apprcpriate, (see above).

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G.

Traininc Training was not evaluated for any of the activities evaluated.

Thus.there is no basis for evaluation.

V.

Conclusions' Based on an liRR evaluation of 14 licensing activities -during the seriod Octcber 1,.1982 through January 31,19E4, the overall perferr.ance rating for GPU !?uclear licensing activities for Three Mile Island Nuclear Station,. Unit 1 is category 2.

The overall rating for each evaluated attribute is category,2.

lio major deficiencies affecting licensing activities becare a; parent during the evaluaticr. period.

GPU iluclear Lshcuid focus on in: roving its environmental cualification program.

The licensee generally devotes an-adecuate level of management involvement to iicensing activities; the licensee's approach to the resciution of technical issues.is generally scund and conservative; anc, the. licensee is generally res:cnsive to SRC initiatives'.

YW IamesA.VanVliet,ProjectManager Operating Reactors Branch #4 Division of Licensing

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