ML20154A803
| ML20154A803 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/09/1988 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| References | |
| NUDOCS 8805160172 | |
| Download: ML20154A803 (2) | |
See also: IR 05000289/1986098
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Docket No. 50-289
GPU Nuclear Corporation
ATTN: Mr. H. D. Hukill
Vice President and Director of TMI-1
P.- 0.. Box 480
Middletown, Pennsylvania 17057
Gentlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP) Report No.
50-289/86-98
.This letter transmits our final SALP Report for Three Mile Island Unit 1.
As in
the past, our overall assessment is that the plant continues to be operated in a
safe manner, with well established programs, a highly competent staff, and is being
maintained in good material condition.
The SALP evaluation for Three Mile Island Unit 1 for the period of November 1, 1986
through October 31, 1987, was initially forwarded to you by our February 11, 1988
letter (Enclosure 1). This SALP evaluation was discussed with you and your staff
at a meeting held on krch 3,1988 (see Enclosure 2 for attendees). Your letter
dated April 5, 1988, which provides your actions and comments regarding the SALP
Report, is attached as Enclosure 3.
These will be placed in the Public Document
Room.
We have reviewed the improvements you have described in your letter and believe
your actions are responsive and will provide future performance improvements. We
also note your comments relative to certain functional areas and acknowledge that
several changes to the SALP Report are appropriate. These changes, dealing with
reactor water level design single failure susceptibility equipment qualification
evaluations, the chlorine detection system, and several other matters are indicated
in the amended report (Enclosure 4).
In summary, we felt the report, our meeting, and your response letter resulted in
a constructive assessment of the performance at Three Mile Island Unit 1.
Your cooperation in the SALP program is appreciated.
Sincerely,
Oricirm1 Signed By
UILLI!.h T. UJSST.LL
William T. Russell
Regional Administrator
0FFICIAL RECORD COPY
DL50-289/86-98 FINAL - 0001.0.0 t(
04/18/88
8805160172 880509
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Enclosures:
1.
NRC Region I letter, W. T. Russell to H. D. Hukill dated February 11, 1988
2.
SALP Meeting Attendees
3.
GPUN Letter, P. R. Clark to NRC dated April 5, 1988
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Systematic Assessment of Licensee Performance (SALP) Amended Report No.
50-289/86-98
5.
Errata Sheets
cc w/encis:
T. G. Broughton, Operations and Maintenance Director TMI-1
C. W. Smyth, Manager, THI-1 Licensing
R. J. McGoey, Manager, PWR Licensing
E. L. Blake, Jr. , Esquire
TMI-Alert (TMIA)-
Susquehanna Valley Alliance (SVA)
Chairman Zech
Commissioner Roberts
Commissioner Bernthal
Commissioner Carr
Commissioner Pogers
K. Abraham, PAO, RI (13 copies)
Public Document Room (POR)
loca'.Public Document Room (LPDR)
Nuclar Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
bec w/ enc 1:
Region I Docket Room (with concurrences)
J. Goldberg, OELD: HQ
J. Taylor, DERO
J. Lieberman, OE
W. Russell, Ri
F.- Congel, DRSS
SALP Management Meeting Attendees
R. Brady, RI
W. Oliveira, DRS
0. Holody, ES
Menagement Assistant, DRMA (w/o enc 1)
ORP Section Chief
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UNITED STATES
ENCLOSURE 1
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NUCLEAR REGULATURY COMMISSION
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REGION I
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475 ALLENDALE ROAD
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XING 0F PRUSSI A, PENNSYLVANIA 194ol
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Docket No. 50-289
E' ' I N
GPU Nuclear Corporation
ATTN: Mr. H. D. Hukill
Director, TMI-1
P. O. Box 480
Middletown, PA 17057
Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP) Report No.
50-289/S6-98
The NRC Region I SALP Board conducted a review on December 8, 1987, and evaluated
the performance of activities associated with the Three Mile Island (Unit 1) Nuc-
lear Generating Station.
The esults of this assessment are documented in the
enclosed SALP report, which covers the period November 1, 1986, to October 31, 1987.
We will contact you shortly to-schedule a meeting to discuss the report.
At the meeting, you should be prepared to discuss our assessment and any plans you
may have to improve performance further. Any comments you may have regarding our
report may be discussed at the meeting. Additionally, you may provide written
comments within twenty days after the meeting.
Your cooperation is appreciated.
Sincerely,
h/
1 - Ed
William T. Russell
Regional Administrator
Enclosure: NRC Region I SALP Report 50-298/86-98
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cc w/ enc 1:
-T. G.' Broughton, Operations and Maintenance' Director, TMI-1
C. W. Smyth, Manager, THI-1 Licensing
R. J. McGeey, Manager, PWR Licensing
Ernest L. Blake, Jr., Esquire
Chairmar ?>ech
- Commissi.ner Roberts-
Commissioner Bernthal
Commissioner Carr -
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Commissioner Rogers
K. Abraham, PAO, RI (14 copies)
Public Document Room (PDR)
local- Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident inspector
Commonwealth of Pennsylvania
TMI Alert
Susquehanna Valley Alliance
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ENCLOSURE 2
LIST OF ATTENDEES
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SALP MANAGEMENT MEETING - MARCH 3. 1988
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GPU Nuclear' Corporation (GPUN)
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P. F. Ahern, Senior Staff Specialist, NSCC-THI
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G. R. Bond, Director, Systems Engineer
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~T.:G. Broughton, Operations and Maintenance Director, TMI-1
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R. P. Clark, President, GPUN .
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D. K. Croneberger,: Director, Engineering Projects
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I.'R. Finfrock, Chairman, GORBs.
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.J. C. Fornicola, Manager, TMI.QA Mods / Ops
R. P. Germann, NSAD Director
0. V. Hassler, TMI-1 Licensing Engineer
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H. D. Hukill, Vice President and Director,'TMI-1
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R. L. Long, V4ce President and Director, Division of Planning and Nuclear Safety
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R. S. Markowski, Manager, QA Program Development and Audit
R. J. McGoey, Manager, TMI Licensing
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G. S. Metsky, Assistant Comptroller
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B. .T. Moroney, Senior Staff Specialist, NSCC-0C
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W. Popow, MCF Production and Technical Director
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L. G. Robinson, Media Relations / Communications
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M. B. Roche, Vice President and Director, Division of Quality and Radiological
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Controls
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C. W. Smyth, TMI Licenst
nager
J. R. Thorpe, Dirc: tor, Licensing ar.d Regulatory Affairs
G. E. VonNieda, Chemistry / Materials Director
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E. G. Wallace, Engineering Services Director
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R. F. Wilson, Vice President and Director, Technical Functions
U.S. Nuclear Regulatory Commission (NRC)
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L. H. Bettenhausen, Chief, Projects Branch No.1, Division of Reactor Projects (ORP)
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R. J. Conte, Senior Resident Inspector, TMI
C. J. Cowgill, Chief, Reactor Projects Section 1A, ORP
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A. W. Oromerick, Project Manager, Oyster Creek, NRR
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R. Hernon, Project Manager, TMI-1, NRR
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W. V. Johnston, Director. 01 vision of Reactor Safety (DRS)
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W. F. Kane, Director, ORP
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W. T. Russell, Regional Administrator
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J. F. Wechselberger, Senior Resident Inspector, Oyster Creek
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ENCLOSURE 3
GPU Nuclear Corporation
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Pa's pcany, Ne* Je'sey 07054
201 316 7000
TEl.EX 136-482
Wr.ter's D rect 0 ai Nurrter.
C311 -88-2034
.pril 5, 1988
U.S. Nuclear Regulatory Ccenission
Attn: Document Control Desk
Washington, D.C.
20555
Gentlemen :
Three Mile Island Nuclear Station, Unit 1
Operating License No. OPA-50
Docket No. 50-289
Response to SALP Report 86-98
On February 11, 1988, the NRC issued the Systematic Assessment of Licensee
Perfomance (SALP) report for Three Mile Island Unit 1.
A meeting to discuss
this report was held in the GPUN corporate of fices on March 3,1988.
The
attachment to this letter provides the GPUN written comments on the SALP
report.
As indicated in the March 3,1988 meeting, we are addressing the
areas identified in the SALP as needing improvement.
We appreciate the opportunity to review with you the SALP report and provide
our coments.
We continue to believe that this dialogue is the most
meaningful portion of the SALP process.
Sincerely,
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P. R. Clark
President
HDH/DVH/feg:
cc: tW. Russell
R, Hernan
R. Conte
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6618f/0167 f Gru N :ea cewat en s a suesa a , ce Genera Put : e:: es corperat.cn
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NiTACHMENT 1
RESPONSE TO SALP REPORT 86-98
A.
Plant Operations
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In general, we are pleased that the NRC noticed and acknowledged
improvements made in Operations. We consider we had a good, safe
operational period and thEt the record supports this.
Our goal is to
continue to improve and strive for excellance.
Specifically we offer the
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following conenents:
1.
, Personnel Errors - Procedural Compliance
We recognize that closer attention to procedural compliance is
requi red.
Guidance in this area will be reinforced to all levels of
supervision.
In addition action will be taken to strengthen the
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procedure preparation and review process especially in the
maintenance area.
2.
Schedular Pressure - Haste - Pace of Activities
Much attention has been directed, particularly since April 1987, to
the need for proper planning and a safe conservative approach to all
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evolutions. We consider that we have been successful in getting this
message to our people, as demonstrated during the letdown cooler
replacement and the recent 3 day stator cleaning outages.
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outages were controlled and conducted in a safe, well planned, and
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coordinated manner.
We intend to continue to apply the principles
used in these short outages and the lessons learned from them.
3.
Self Evaluation of Less Significant Problems
We acknowledge that more attention to and evaluation of day-to-day
unusual events in the plant are needed.
We use the formal Plant
Incident Report (PIR) for a thorough evaluation of the more
significant events.
This is the proper use of the PIR system.
However, we understand and agree events of lesser significance need
more visibility at all levels of management 50 that lessons learned
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can be communicated and that unfavorable trends can be identified and
appropriate action taken.
We are currently working to detemine the
best way to implement such a program with minimal adninistrative
impact. We expect to have a program in place by July 1,1988.
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B.
Radiological Controls
We are in general agreement with the analysis as presented.
The facts as
we know them regarding the letdown filter cubicle (page 17, first full
paragraph, and page 18, last sentence) do not indicate management
inattentiveness.
This is a complex job and we have properly performed
seventeen filter changes subsequent to the incident demonstrating that
sufficient attention has been provided to resolve the problems.
C.
Maintenance
We are pleased that the NRC views the Maintenance Department as a
positive influence on overall plant performance.
The recently
established Materiel Department, we believe, will provide us with even
better long term plant reliability which will enhance safety. We offer
the following specific connents:
1.
Final Closeout of Job Tickets
We acknowledge that in some cases there has been excessive delay in
closing out job tickets.
Steps have already been taken to correct
this area.
2.
Vendor Cannunications/ Interface Problems with the Major Emergency
Diesel Generator Maintenance
We consider this to be an isolated incident that was probably
exacerbated by schedular pressuces.
We clearly understand our
responsibilities for control of contractor work and verification of
accuracy of information supplied by contractors.
This will be
emphasized to all on site managers prior to the 7R outage.
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O.
Surveillance Testing
No comment,
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E.
Fire Protection
The Fire Protection area is one which has had a great deal of attention
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over the past years.
There was a large amount of work done in support of
Appendix R requirements. While we acknowledge specific deficiencies, we
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do not agree with the suggestion that there is a similarity in problems
with the Environmental Qualification (EQ) area.
The probleas noted in
the SALP were more isolated and in our view should not be compared with
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the EQ area.
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F.
We have taken action to correct the items cited.
We have a Tech. Support
Center (TSC) calculation handbook being developed and selected members of
the TSC staff will visit other utilities' facilities to observe good
practices that could benefit our TSC. We now have two primary methods to
activate the Parsippany Technical Functions Center as well as a backup
method which should eliminate any delay in having that center activated,
although it should be noted that the activation times in the plan have
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always been achieved.
G.
Security and Safeguards
No comment.
H.
Outages
We believe our outages during the last year; 6R, Letdown Cooler and
Stator Cooling, were well planned and conducted properly. The 7R outage
has better planning and preparations are more extensive which should
result in an even better outage.
Our test program is an integral part of our modification process.
At
times this test program will uncover problem areas.
However, we will
continue to emphasize to our people the importance of proper reviews of
modifications to find and resolve potential problems prior to
installation and testing.
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Outage work packages have previously remained open too long. Emphasis is
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being placed on close out of Maintenance job tickets and a new
modification package process has been developed to assure a more timely
close out of modification packages consistent with the completion of the
outage.
I.
Licensing Activities
We have three detailed coments to the SALP in this area:
1.
Although the methods to meet Appendix R requirements are still being
reviewed, GPUN considers that we have satisfied the Appendix R
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requirements.
2.
The time NRC had to approve the pressure-temperature amendment
appears inaccurate.
GPUN submitted the request July 24, 1987 and the
amendment was issued November 18, 1987.
This is 17 weeks as compared
to the stated 10-11 weeks (2-1/2 months).
Perhaps there is a problem
with the receipt of mail.
GPUN will follow-up on critical license
submittals to assure they have been received,
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3.
On the Chlorine Technical Specifications, GPUN has never comitted to
meeting Reg. Guid.31.95 requirements.
Therefore, our submittal would
not have provided the justification looked for by the NRC.
J.
Engineering Support
Consistent with the previous SALP, we have been performing a self
assessment of the engineering support area.
Phase I consisted of a
structured survey of the engineering staff and the "user comunity." The
summary of results is completed and the final phase, including
conclusions and action plan is to be complete by May. We look fomard to
reviewing the results of this assessment with your staff.
We are addressing the NRC coments in five areas (1) Engineering Staff
Accountability; (2) Yendor Control (both suppliers of engineered
equipment and Architect / Engineers); (3) Schedule Insensitivity related to
backlog, NRC issues, and modification engineering; (4) Comunications
between design organizations with other functional groups, and (5)
Technical Reviews.
We have been working to improve these areas by the following actions:
(actions already implemented)
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Modi fications
Implemented program changes to:
Stop splitting design responsibility between Architect
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Engineers / Contractors on individual modifications.
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Move to use only one A/E per plant for design work
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not performed by GPUN.
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Enhanced design reviews with stronger and earlier operations /
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maintenance input.
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Enforce Plant walkdowns by design organization.
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Establish schedules to ensure earlier release (target of 6 months)
prior to an outage.
Continually implement corrective actions based upon analysis of
quality trends.
B_acklog
Focus resources to further reduce engineering action items.
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Configuration Control
- Design Document Data Base (CARIRS) improved to further address user
issues.
- Vendor Manuals - Essential manuals have been reviewed and
controlled.
- Completed Equipment Level Quality Classification List and
Engineering Data Base.
Approximately 25,000 components have been
entered into the Engineering Data Base.
Owners Group
Increase focus on Owners Group and taking leadership role in them.
Management will continue to emphasize the need for thorough and timely
responses to technical issues by including:
1.
Prompt implementation of action plans developed as a result of the
self assessment.
2.
Emphasizing the need for Operations and Maintenance input on plant
modifications by adherence to procedural requirement for design
revi ews.
3.
Strengthen technical and safety reviewer training.
4.
Continue che focus on timely reduction of backlog.
5.
Extend the sound technical support provided by the Startup and Test
organization to shop testing of engineered vendor hardware.
We do tve some specific coments regarding specific issues identified in
the SAU report.
The last paragraph on page 40 states in parts:
"These deficiencies led to licensee having to perfom additional
testing of quality materials as a result of an NRC evaluation
perfomed during the period."
GPUN is unaware of the instance (s) cited.
There were no instances
where GPUN perfomed additional testing.
There was one instance
where GPUN had to perfom further evaluation of a part in a
component. We assume this is the instance being cited in the THI-1
SALP.
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The first paragraph on page 40 of the SALP makes reference to the reactor
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water level design having problems.
TNI-1 was required to complete NURFG 0737 item !!.F.2 prior to
restart from Outage 6R.
During an October 2,1986 meeting, the NRC
identified disagreement with the GPUN approach in that RCITS water
level input signals to the plant computer enter a single multiplexer
and are displayed through two computers.
The NRC disagreed with this
configuration on the basis that it did not satisfy the single failure
cri terion.
GPUN maintained that this configuration meets the
requirements of NUREG 0737 item II.F.2 and that RCITS does not
constitute accident monitoring instrumentation, and therefore, the
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single failure criterion does not apply.
GPUN continues to believe
the design as described is adequate. To'date the NRC has not
documented a finding that the RCITS design as installed is
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unacceptable.
In addition, GPUN does not believe that a correlation exists between
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the design of the reactor coolant inventory trending system and
perceived difficulties with the safety review process.
X.
Training and Qualification Effectiveness
In response to the NRC recomendation for the licensed operator
requalification examinations, a requirement has been established, as
documented in the licensed operator requalification training program
description, that examinations should emphasize the operational
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application of theoretical concepts and the application of facility
administrative limits, Technical Specifications, etc., rather than
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n*morized lists of numbers and facts.
Further, steps are being taken to
upgrade learning objectives and test items.
L.
Assurance of Quality
We are in general agreement with the analysis portrayed although we
believe the management attitude problem portrayed is an isolated one and
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one in which the company is actively working to resolve.
We do not
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believe this problem is manifested in the upper levels of site management.
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The safety review program is an area where dialogue has been continuing
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with the NRC, At this time we do not offer any coments other than this
area has had and will continue to have a great amount of management
attention.
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