ML20150A743
| ML20150A743 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/23/1988 |
| From: | Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20150A734 | List: |
| 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:
A3 8[
C. Cokgillfi9hief, Reactor Projects Section No. IA
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One item was retracted by NRC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
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
safety], then the STP will be classified as ITS."
Interim guidance at
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TMI-1 Division is that ITS classified systems will get a "Form (Figure)
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4" (safety determination -- first form) and a "Form (Figure) 5" (safety
evaluation -- second form) review which includes a 10 CFR 50.59 safety
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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,
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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
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:
R. Germann, Nuclear Safety Assessment Director
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S. Kowkabany, Licensing Engineer
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R. McGoey, Manager, PWR Licensing
M. Nelson, Safety Review Manager
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C. Smyth, TMI Licensing Manager
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The inspection re:ults are summarized in the cover page of the inspection
report.