ML20153C412
| ML20153C412 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/10/1986 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 5211-86-2019, NUDOCS 8602190219 | |
| Download: ML20153C412 (10) | |
Text
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GPU Nuclear Corporation NUC Mr Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057 0191 717 '44 7621 TELEX 84 2386 Writer's Direct Dial Number February 10, 1986 5211-86-2019 Dr. Thomas E. Murley Region I, Regional Administrator U.S. Nuclpy Regulatory Commission
. 631 Park Avenue King of Prussia, Pa.
19406
Dear Dr. Murley:
Th"ee Mile Island Nuclear Station Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Notice of Violation Response for Inspection Report 85-27 Attachment A to this letter is GPUN's response to Appendix A of Inspection Report No. 50-289/85-27 " Notice of Violation" with the exception of part C which will be submitted by February 18, 1986 as discussed with R. Conte of Region I on February 10, 1986.
Sincerely, D.
11' Director, TMI-l HDH/MRK/',,o cc:
W. Kane R. Conte Sworn and Subscribed to Before Me This / o *C Day 0485A of b]n ugt
, 1986.
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ATTACHNENT A I
FINDING:
A.
Technical Specification 6.8.1 states, " Written procedures important to safety shall be established, [and] implemented... covering the...
applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February,1978...."
1.
App 2'
- x A of Regulatory Guide 1.33, Revision 4, recommends that operation of the control rod drive system and the liquid radioactive waste system be covered by written procedures.
Contrary to the above:
a.
On October 23, 1985, an operation involving the overriding of the safety rods out interlock for the control rod drive system was conducted without the use of a written procedure; and b.
On November 1,1985, an oxygen sample was taken from the reactor coolant drain tank without the use of a written procedure.
This operation resulted in the inadvertent draining of one-leg of differential flow transmitter 922, making this reactor coolant safety valve flow instrument inoperable until the leg was refilled later the same day, 2.
Administrative procedure 1001G, Revision 10, January 30, 1985,
" Procedure Utilization," paragraph 3.1.5. states, in part, that if the individual actually performing the activity cannot or believes he should not follow the procedure governing that activity as written, he shall place the system / component into a stable and safe condition and expeditiously inform the supervisor responsible (for resolution).
Contrary to the above:
- a. -On November 1 and 6,1985, during the lineup for a liquid release from the waste evaporator condensate storage tank per operating procedure 1104-298, procedure steps 1.3. A, B, C could not be implemented as written and the supervisor was not contacted to resolve the discrepancy.
b.
On November 12, 1985, the pre-inspection lineup for emergency diesel generator 1B could not be implemented as written and the supervisor was not contacted to resolve the discrepancy.
lt Collectively, items A.1 and A.2 represent a Severity Level IV Violation (Supplement I).
I 4
l E
RESPONSE
A.
1.
GPUN disagrees with Finding A.l.
The two operations discussed in Finding A were performed by individuals qualified to perform these.
Guidance exists in the Operatio al Quality Assurance Plan, Sections 6.11.1.2 and 6.11.1.3 and Administrative Procedure AP 100lG,
" Procedure Utilization," Section 3.3.4, which allows qualified personnel possessing the appropriate skills to perform maintenance work without step-by-step delineation in a written procedure.
Although we feel the individuals acted appropriately in performing the operations as they did, additional guidance will be provided for personnel performing troubleshooting maintenance activities.
A.
2.
Operating Procedure 1104-29S was incorrectly identified as Procedure 1104-298 in Finding A.2.a.
(1 ) Corrective Steps Which Have Been Taken As documented in Inspection Report 85-26, a procedure change request was initiated to correct the discrepancy identified in operating procedure OP 1104-29S.
Surveillance Procedure SP1301-8.2, " Diesel Generator Annual Inspection," will be revised to correct the discrepancy identified.
As requested in the cover letter to Inspection Report 85-27, the following corrective actions address the GPUN response to this finding and the actions taken to assure personnel understand the procedure control program, and the steps taken to assure implementation of the program.
Sufficient controls are in place in AP 1001 G to assure future procedure adequacy problems are identified and resolved prior to implementa tion.
The Director, TMI-l discussed procedure compliance with Maintenance and Operations personnel during the timef rane of November 26 to December 30, 1985 as part of the corrective action for the response to the violation in Inspection Report 85-22. The discussions included the need to correct procedure deficiencies and discrepancies identified using the TCN and PCR systems.
In addition, Quality Assurance monitoring personnel are continuing, as part of the corrective action in IR 85-22, to document when procedures are found to be unable to be implemented as written.
These monitoring reports are provided to the Director.
(2.); Corrective Action That Will Be Taken No-further action is considered necessary in addition to the actions described above. The QA monitoring reports will be provided to the Director until he feels it is no longer necessary.
(3) Date When Full Compliance Is Achieved The controls in AP 1001 G have been discussed with personnel and are now being implemented, therefore, we feel compliance has been achieved. Any procedure deficiencies will be corrected'as they are identified.
c FINDING:
B.
Technical Specification 6.5.4 establishes certain requirements for the Independent Onsite Safety Review Group (IOSRG). Technical Specification 6.8.1 requires, in part, that procedures covering safety review activities be implemented. Facility procedure 6310-ADM-1010.01,
" Independent Onsite Safety Review Group Procedure - THI-1," Revision 3, June 19,1985, also describes requirements to be implemented by IOSRG.
Contrary to the above, certain 10SRG requirements as set forth in Technical Specification 6.5.4 and facility procedure 6310-ADM-1010.01 were not implemented as evidenced by the following examples.
1.
Facility procedure 6310-ADM-1010.01 specifies that the periodic review functions of the 10SRG be performed on a selective and overview basis. The procedure also specifies that the Manager, Safety Review, determine the _ items for review and the schedules for evaluations and assessments to implement the periodic review requirements.
However, as of November 15, 1985, no schedule for evaluations and assessments ta implement the periodic review requirements had been prepared by the Manager, Safety Review.
As a result, no periodic review of the required functional areas had been performed.
2.
Technical Specification 6.5.4.6 requires that reports of evaluations and assessments of the functional areas requiring review by the IOSRG be prepared, approved and transmitted to the Nuclear Safety Assessment Director, TMI-1,. and Nuclear Assurance Division Vice President, and the management positions responsible for the areas reviewed.
However, during the period of January 1984 to November 1985, reports were generated by IOSRG in the form of memoranda, but there was no indication of report approval and distribution of these reports was not in accordance with the technical specification distribution requi rements.
3.
Facility procedure 6310-ADM-1010.01, step 4.4.2, requires, in part, that "Recommndations prepared by the 10SRG based on evaluations, assessments, and reviews... be approved by the Manager, Safety i
Review, and transmitted to the Nuclear Safety Assessment Department Director and the management positions, including the division director /vice ' president, responsible for the areas reviewed." Also, step 4.5.1 of the procedure requires, in_ part, that records,
"... shall include... recommendations to management and the results of such recommendations."
4 However, IOSRG records for the period January,1984 to November,1985 showed no method of approval of recommendations exists, recommendations are not always clearly identified, recommendations are not always transmitted as specified and results of 1
l recommendations are not maintained.
i
4.
Facility procedure 6310-ADH-1010.01, step 4.3.4 states, "The 10SRG shall review all safety evaluations involving unreviewed safety questions or technical specification changes and concur with safety evaluation conclusions or provide comments for resolution."
. Step 4.5.2 of the procedure requires a safety review sheet, form 6310-ADM-1010.01 -03, be completed for each 10SRG review of safety evaluations involving technical specification changes.
However, between July 20, 1984, and October 31, 1985, seven technical specification changes were submitted to the NRC, but only two of-those changes, technical specification change requests 141 and 146, had safety review sheets completed.
Collectively, items B.1 through B.4 represent a Severity Level IV Violation (Supplement I).
RESPONSE
B.
GPUN agrees in part with the findings cited in Violation B.
Certain aspects of the findings, however, are basr an interpretations which we believe differ from the intent of TMI-1 Technical Specifications (T.S.)
6.5.4 and GPUN procedures. These are the procedure which implements the safety review process (1000 ADM 1291.01) and the precedure which implements T.S. 6.5.4 (6310 ADM 1010.01).
- The third paragraph of the cover letter for IR 85-27 appears to be confusing the objectives of the safety review process with the responsibilities of the IOSRG. This reflects the interpretation that the Independent Onsite Safety Review Group (IOSRG) is responsible for conducting thorough reviews of all TMI-1 procedures for clarity and adequacy.
T.S. 6.5.4.3 states that one of the periodic review functions of the IOSRG includes evaluation for technical adequacy and clarity of procedures important to the safe operation of the unit on a selective and overview basis.
It is IOSRG's' responsibility to identify in its assessments and evaluations any problems of technical adequacy and clarity which may be generic to the procedure review process.
Procedural-adequacy is the responsibility of the procedure owner, who is aided by the input, reviews, and approvals provided by the Safety Review Process (1000 ADM 1291.01) and various division implementing procedures.
It is not the responsibility of the 10SRG to thoroughly review all i mcedures for clarity and technical adequacy.
10SRG provides an autional level of review on a selective basis that is beyond the safety review process.
10SRG does not provide the functions of the Independent Safety Reviewer (ISR). We feel -that this and other interpretive differences are what led to the negative statements about 10SRG performance in IR 85-27.
At the time of the inspection, GPUN had not documented its interpretation of certain words in procedure 6310 ADM 1010.01. This appears to have caused some of the confusion which has resulted in this violation.
These ambiguities are discussed as follows:
(a) Schedule - The procedure states that the Manager, Safety Review determines the items for review and the schedules for evaluations and assessments to implement the periodic review functions.
It was never intended that scheoules be drawn up or formalized.
In this context, the word " schedule" is used to show the degree of management control over IOSRG activities exercised by the Manager, Safety Review. The word " schedule" does not appear in T.S. 6.5.4.
(b) Periodic - T.S. 6.5.4.3 specifies the periodic review functions which must be conducted by 10SRG on a selective a'nd overview basis.
These review functions are performed by 10SRG on a continucus basis.
Our method of accomplishing the periodic review functions had not been documented.
Improvements in this area will be accomplished pursuant to Section II.2 of the corrective action.
(c) Reports - T.S. 6.5.4 requires that reports of evaluations and assessments of the functional areas requiring review by 10SRG be prepared, approved, and transmitted in a prescribed manner.
Reports of IOSRG evaluations and assessments in summary form have consistently been prepared, approved and transmitted as required by T.S. 6.5.4.
At the time of the inspection, GPUN had no documentation indicating that these are the only reports which are required by T.S. 6.5.4.
Another source of confusion was the fact that GPUN changed the frequency of these reports from monthly to bi-monthly and the procedure (6310 ADM 1010.01) had not been revised to reflect this change. Therefore, these reports were not being issued in accordance with the procedural requirements.
Without clear definition that these reports were those intended to fulfill the T.S. requirement, one could interpret the word " report" to mean any memorandum prepared by any 10SRG member including file memoranda prepared simply to document background information in a retrievable form.
It is clearly not the intent of T.S. 6.5.4 that every memorandum prepared by a member of IOSRG be approved by the Manager, Safety Review and given a prescribed distribution.
(d) Recommendations - The procedure (6310 ADM 1010.01) requires that recommendations prepared by the 10SRG based on evaluctions, assessments and reviews be approved by the Manager, Safety Review, and transmitted in a prescribed manner.
T.S. 6.5.4.4 requires only that, based on its reviews, IOSRG provide recommendations to the management positions responsible for the areas reviewed.
All IOSRG correspondence during the period January 84 through November, 85 addressed to persons outside the group has been reviewed to determine the level of compliance with these requirements.
Based upon our review of these documents, we feel that the T.S. requirements have been met.
However, the practice which has evolved for handling recommendations has not been made a part of the procedure. Whether or not the procedure has been violated depends on what constitutes a recommendation or simply may have been a question or concern that was answered or sufficiently addressed in some manner and did not need to be pursued by the 10SRG. We believe that the intent of the procedure has been met.
Documentation was reviewed for all technical specification changes submitted to NRC between July 20, 1984 and October 31, 1985 to determine whether reviews were conducted by IOSRG. We found the documentation to verify that the 10SRG reviewed all of these submittals.
- However, completion of 5 out of 7 of these reviews was not appropriately documented using the form required by the procedure.
Improvements in this area will be accomplished pursuant to Section II.6 of the corrective action.
GPUN believes that the violation and findings as described in IR 85-27 are to a large extent the result of inadequate procedural guidance which has caused inconsistencies, lack of uniformity, and/or lack of adequate documentation.
The lack of adequate documentation to demonstrate the level of compliance actually a'chieved has contributed to the perceived poor performance of 10SRG as concluded by IR 85-27 We feel that the improvements described below will accomplish the required corrective action.
I.
Corrective Steps Which Have Been Taken and the Results Achieved GPUN has reviewed 10SRG activities and practices demonstrated through the group's correspondence, documentation, and follow-up tracking system in order to determine the adequacy of the procedure and practices as well as the level of compliance with the procedure and T.S.
Each of the findings described in the violation and discussed in other sections of IR 85-27 has been examined to determine what changes are needed in order to comply with the requirements and improve the consistency and quality of documentation used to demonstrate compliance.
II. Corrective Steps Which Will Be Taken To Avoid Further Violations Revision of the 10SRG procedure (6310 Ami 1010.01) was in progress but incomplete at the time of the inspection. As a result of the reviews and discussions'which have taken place to address the IR 85-27 findings in the area of the IOSRG, improvements in the practices and procedure of the 10SRG are still in progress.
Sone of these improvements which will be taken to avoid further violations are as follows:
(1 ) Procedural clarification so that use of the word " schedule" is unambiguous.
(2) An administrative procedure will be written to describe and document the periodic reviews performed by 10SRG.
(3) Procedural clarification to specify which reports are those that satisfy T.S. 6.5.4.6 requirements for reports of the 10SRG evaluations and assessments.
(4) Procedural clarification to specify the appropriate distribution for 10SRG correspondence.
(5) Procedural clarification to ensure uniformity and consistency in the documentation and handling of 10SRG recommendations.
(6) Procedural clarification to ensure uniformity and consistency in the documentation and handling of 10SRG's rev'ews of safety evaluations involving unreviewed safety questions or technical specification cha nges.
III. Date When Full Compliance Will Be Achieved Procedure 6310 ADM 1010.01 will be revised to incorporate the necessary cha nges. This revision will be completed by April,1986.
r
.,s FINDING:
D.
The Three Mile Island Nuclear Station, Units 1 and 2, Modified Amended Physical Security Plan requires, in part, that all personnel in protected and vital areas display their photo identification badges.
Technical Specification 6.8.1.d requires, in part, that written procedures be implemented covering security plan implementation.
Security procedure 1005.11, " Access to Protected / Vital Areas," Revision 36, dated July 29, 1985, states in part that all personnel entering THI-l protected areas shall display their photo identification badge except under certain specified conditions that permit the badge to be removed and secured in the owner's pocket.
Contrary te the above, on November 15 and 18,1985, photo identification badges and keycards were found attached to garments on a rack at an unattended changing station, and therefore were not on the individuals.
Further, between November 20 and 27,1985, certain employees were in the instrument and control shop and the control room and their photo identification badges were not displayed or secured in their pockets.
This is a Severity Level V Violation (Supplement III).
RESPONSE
1.
Corrective Steps Which Have Been Taken and Results Achieved During the period of December 2,1985 to December 20, 1985, the Director, TMI-1 discussed the proper wearing of the Protected Area badge with personnel.
This has also been discussed in one of the Director's Site Managers meeting.
In. addition, guidelines for wearing a Protected Area badge, including the circumstances when it is acceptable not to display the badge, were distributed to all badge holders.
2.
Corrective Steps Which Will Be Taken to Avoid Further Violations No further action is planned beyond instructing personnel on proper wearing of badges as part of annual general employee training.
3.
Dr.te When Full Compliance Will Be Achieved With the completion of the above corrective actions, compliance has been achieved. However, we see this as being a potentially reoccurring problem due to unintentional noncompliance.
1 i