ML20150A743

Safety Insp Rept 50-298/88-04 on 871013-15 & 0205.Major Areas Inspected:Licensee 870828 Response to 870729 Notice of Violation Re Adequacy & Proper Implementation of Licensee Technical & Safety Review Program

ML20150A743
Person / Time
Site:	Three Mile Island
Issue date:	02/23/1988
From:	Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20150A734	List: IR 05000289/1988004 ML20150A743
References
50-289-88-04, 50-289-88-4, NUDOCS 8803160025
Download: ML20150A743 (5)

See also: IR 05000298/1988004

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U.S NUCLEAR REGULATORY COMMISSION

REGION I

Docket / Report No. 50-289/88-04 Licensee: DRP-50

Licensee: GPU Nuclear Corporation

P. O. Box 480

Middletown, Pennsylvania 17057

Facility: Three Mile Island Nuclear Station, Unit 1

Location: Middletown, Pennsylvania

Dates: October 13-15, 1987, and February 5, 1988

Reporting

Inspector: R. Conte, Senior Resident Inspector

Approved by:

C. Cokgillfi9hief, Reactor Projects Section No. IA

A3 8[

Date

Inspection Summary:

This was a special safety inspection to review the licensee's response, dated

August 28, 1987, to an NRC issued Notice of Violation, dated July 29, 1987 (NRC

Inspection Report No. 50-289/87-08). This dealt with the adequacy and proper

implementation of the licensee's Technical and Safety Review Program (TSRP). The

initial review of the licensee's response necessitated an additional inspection

at both the site and at the corporate office.

In_soection Results

The licensee denied a majority of the items cited. One item was retracted by NRC

staff due to unsubstantiated information. Licensee corrective actions were sum-

marized; but, in certain instances, more specific information was needed. The

adequacy and proper implementation of the licensee's TSRP remains open pending a

forthcoming management meeting in Region I and pending subsequent inspection veri-

fication of licensee actions.

8803160025 880307

PDR ADOCK 05000289

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DETAILS

1. Introduction and Overview

The purpose of this inspection was to review the licensee's response to a

Notice of Violation issued by Region I on July 29, 1987. This concerned the

adequacy and implementation of the licensee's Technical and Safety Review

Program (TSRP) in which specific findings were first identified during a per-

formance appraisal team inspection in September 1986. The licensee's response

to the violation was dated August 28, 1987.

As a result of NRC staff initial review of the licensee's response, it was

determined that additional information was needed to better understand the

licensee's response and/or corrective actions. Accordingly, in conjunction

with a corporate inspection in October of 1987 (NRC Inspection Report No.

50-289/87-19), additional information related to licensee response was ob-

tained as documented below.

2. (0 pen) Violation (289/87-08-01): Failure to Properly Document and Implement

the Technica' and Safety Review Program for Facility Modifications and

Procedure Changes

2.1 General Corrective Actions

During this inspection period, the inspector reviewed the licensee's re-

sponse, dated August 28, 1987, to the cited Notice of Violation. The

licensee disagreed with essentially all parts of the violation, except

on the one issue (Notice Item No. 2.a) on failure to properly classify

special temporary procedures (STP's) which resulted in no safety evalu-

ation documentation for the subject STP's.

For item 2.a, the licensee's letter indicated that both immediate cor-

rective action and measures to prevent recurrence (although not specific-

ally stated as such) were to issue initial and final (procedural) guid-

ance on the classification of STP's. Since this was not specific, the

inspector reviewed Administrative Procedure (AP) 1001A, Revision 13,

dated June 26, 1987, "Procedure Review and Approval," Enclosure 4. The

inspector found that guidance was "in most cases, if an affected system

corresponding operating procedure is classified as ITS [important to

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safety], then the STP will be classified as ITS." Interim guidance at

! TMI-1 Division is that ITS classified systems will get a "Form (Figure)

! 4" (safety determination -- first form) and a "Form (Figure) 5" (safety

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evaluation -- second form) review which includes a 10 CFR 50.59 safety

evaluation. In the interim, this action resolves the specific concern

but addressed below is a brcader issue on the use of safety deterair,stions

(SD's) in distinction to safety evaluations (SE's) as defined by the

licensee.

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Also, in the licensee's response, the licensee claims no Temporary Change

Notice (TCN) misclassification occurred as identified by Quality Assur-

ance (QA) Department. This statement was confirmed by the licensee's

QA audits supervisor. The applicable inspection reports were not speci-

fic as to which TCN's were misclassified. Accordingly, this portion of

the violation is considered to be retracted.

, In an attempt to resolve the fundamental issues of the cited violation,

the inspector identified the following corrective actions (summary).

Response to Notice of Violation Item No. 1

(1) The subject air-operated valve positioner used in the emergency

feedwater (EFW) system was replaced by another positioner, but the

licensee does not state whether or not the related safety evaluation

substantiates its use as an adequate replacement-in- kind consider-

ing appropriate safety grade criteria.

(2) During the corporate visit addressed in NRC Inspection Report No.

50-289/87-19, Section 5, the inspector learned of an additional

action which is not specifically stated in the licensee's response

letter. Revisions to safety evaluations will get a new Form 1/2,

"Safety Determination / Evaluation," for each subsequent revision.

Response to Notice of Violation Item No. 2

(3) The applicable corporate procedure would be revised to require an

explicit statement for negative responses on the SD (Form 1 of the

two-step process). Form 2 is the SE which applies the remaining

10 CFR 50.59 question with respect to unreviewed safety questions.

(4) Development of guidance with respect to the definition of Licensing

Basis Documents (LBD) but specifics are not stattd (t cresch ed item

No. 289/87-08-02).

(5) Self-assessment of the effectiveness of the safety review process

but specifics are not stated.

(6) S i '. dministrative Procedure (AP) 1001J and Corporate Procedure

$P-L are being revised to define the process of safety review for

all test procedures generated by startup and test, which may or may

not be used to satisfy required technical specifications or sur-

veillance testing.

Items (1), (2), and (6) will be verified in a subsequent inspection as

follow-up to this item. Item (3) above was verified by review of Revi-

sion 3, dated October 1, 1937, to Corporate Procedure 1000-ADM-1291.01,

"Procedure for Nuclear Safety and Environmental Impact Review and Ap-

proval of Documents." With respect to items (4) and (5), additional in-

formation is needed from the licensee detailing the scope of the programs.

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2.2 Safety Evaluation Process

With respect to item (1) of paragraph 2.1 for procedural changes, a fun-

damental problem still exists. It centers around the corrective action

to explain the "NO" answers of the Fs in meeting the requirements of

applicable TS and 10 CFR 50.59. The NRC staff expects all changes, to

safety-related procedures (in TMI-l's case, important-to-safety proce-

dures by TS 6.8.1) receive a safety evaluation eppropriate to the cir-

cumstances using as a minimum the basic questions / criteria of 10 CFR

50.59 (TS 6.8.2).

More specifically, the licensee's program would not necessarily achieve

these results based on a review of licensee's response letter and proce-

dural guidance. The licensee's SD Form Question No. 5 asks whether or

not the document or change (under review) requires a revision to any pro-

cedural or operating description in the Final Safety Analysis Report

(FSAR), TS, or LBD. The licensee had not mandated to its personnel to

broadly consider the required procedures of TS 6.8.1 to be a part (by

reference) of the FSAR or LBD. Literally, since very few specific pro-

cedures are described in the FSAR, TS, or LBD, a "NO" would usually be

answered on the SD and the safety evaluation (second form) would not have

to be completed for a substantial change to a safety-related procedure.

Another SD question that could possibly trigger the use of the SE is No.

3, which asks broadly "does this document or change have the potential

to adversely affect nuclear safety or safe plant operation." The accom-

panying procedural guidance asks personnel to consider overall effect

on safety-related equipment by one example, such as scaffolding over

safety-related equipment. However, there is no requirement to explain

a "NO" answer to the question. A "YES" answer on the SD would trigger

the safety evaluation consistent with 10 CFR 50.59. In light of this

existing licensee guidance, answering question 3 would be highly judg-

mental and it would not guarantee a consistent level of performance in

justifying no affect on safety.

For example, licensee personnel may change the operating procedure or

create a special procedure for a makeup and purification (MU) (high

pressure safety injection) pump to rely on the auxiliary gear oil pump

for operability during power operations instead of the shaft-driven gear

oil pump. The safety significance of the action is that the auxiliary

gear oil pump is not environmentally qualified (licensee letter of

November 9, 1984). It is not clear that the safety determination form

(alone) would trigger a detailed review to uncover the licensee-related

procedural commitment of declaring the MU pump inoperable if the shaft-

driven gear oil pump were inoperable. The safety evaluation form more

adequately prompts the responsible technical reviewer to research the

design basis for the subject pumps.

Additional NRC staff review is needed to address the adequacy of the

licensee's TSRP.

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2.3 Draft Technical Specification

During the above-noted corporate inspection, the licensee also indicated

that a Technical Specification Change kequest (TSCR) is forthcoming to

clarify the original intent of the current Technical Specifications (TS)

on the TSRP.

In December of 1987, a licensee representative provided the inspector

a draft copy of the above-noted TSCR. It is not clear that the draft

TSCR clarifies the original intent of current TS on this matter. This

item will be referred to the Office of Nuclear Reactor Regulation (NRR).

2.4 Additional Clarification

Further, in response to Notice of Violation Item No. 2.c, a statement

was made by the licensee on page 9 of their response with which NRC Re-

gion I disagrees. They state: "Neither 10 CFR 50.59 nor the TMI-1 Tech-

nical Specification require documentation of the basis for a conclusion

that a change does/does not conflict with Technical Specification com-

pliance." If a procedural change conflicts with current TS and does not

specifically conflict with the related TS basis, it is still the licen-

see's responsibility to identify that conflict and resolve it. Implied

in 10 CFR 50.59 requirements to justify no conflict with the basis of

the TS is the need to justify no conflict with the TS. It remains un-

clear what the licensee intended to say by this statement even after

discussiori with licensee representatives

2.5 Conclusion

In conclusion, the licensee's response does not justify retraction of

the violation (except as noted above in paragrar;h 2.1) The licensee is

using a TSRP that is currently unapproved by NRC staff.

The violation remains open pending: (1) ins, actor verification of ac-

ceptable corrective actions as noted above; (2) licensee clarification

on issues so stated above; and (3) results of a forthcoming management

meeting with NRC staff to discuss this matter.

3. Exit Interview

The inspector and Mr. C. Cowgill, Region I discussed the inspection scope and

findings with the following licensee representatives at a final exit interview

conducted by telephone on February 5, 1988:

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R. Germann, Nuclear Safety Assessment Director

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S. Kowkabany, Licensing Engineer

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R. McGoey, Manager, PWR Licensing

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M. Nelson, Safety Review Manager

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C. Smyth, TMI Licensing Manager

The inspection re:ults are summarized in the cover page of the inspection

report.