ML20197A631

Responds to NRC 971008 NOV & Proposed Imposition of Civil Penalties for Insps on 961112-970528.Corrective Actions: Completed Bwst Drawdown Analysis Which Models Revised Operator Actions Specified in Item 2

ML20197A631
Person / Time
Site:	Three Mile Island
Issue date:	12/15/1997
From:	Langenbach J GENERAL PUBLIC UTILITIES CORP.
To:	Lieberman J NRC OFFICE OF ENFORCEMENT (OE)
References
50-289-96-201, 6710-97-2483, NUDOCS 9712230110
Download: ML20197A631 (32)

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-NUCLEAR. M ddletown, PA 17057 04L1 Tel717 944 7621 December 15, 1997 6710 97 2483 hir. James Lieberman Director, Office of Enforcement, USNRC One White Flint North 11555 Rockville Pike Rockville, h1D 20852 2738

Subject:

' Three hiite Island Nuclear Station, Unit 1 (Thil-l)

Operatmg License No. DPR-50 Dochet No. 50 289 Re, . to Notice of Violation Contained in the October 8,1997 Letter, " Notice of Violation and Proposed imposition of Civil Penaltics - $210,000"

Dear Sirs:

Attached is the GPU Nuclear reply to the Notice of Violation (NOV) contained as an enclosure in the October 8,1997 Letter, " Notice of Violation and Proposed imposition of Civil Penalties - $210,000." The NOV response is presented in five sections; with the violations restated in italicized form at the beginning of each section, followed by the GPUN response for that section.

Sincerely, Wil.d Y fM ik 21LSY James W. Langenbach Vice President and Director, Thil 3

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cc. - Document Control Desk i Region i Administrator /' j TMl Senior Resident Irispector v lI

-TMI ! Senior Project Manager rile 97097 '.((\.\g}e{[elllc l Oh D l, x _

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- ATTACHMENT I

.6710 97-2483 Page.1of?l' NOTICERF I 70LA T10N A h") PROPOSED IAfPOS!Tio.h 0FCH7L LMALTIES ,

Durmg NRC inspeenons ccnducted between Nowntberi2,1996. and Afaj 28,1997, violationiofNRC -

requirements were identihed in accodmce with the " General Statemt nt ofPcticy andProcedure)br.

NRC Enforcement Acnons,"NUki: ^. 1600. the Nuclear Regulatory Co sumisstor. proposes to impose civil

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penalties pursuant to Section 234 ofthe Atomic Energy Act qf1934, as amended (Act). 42 U.SC. 2282.

and 10 CFR 2203. The particadar violations and associated civilpent Itics are ietforth below.

' (rollowing each violation section is GPU Nuclear's response.).

Section I. 10 lOLA 770NS ASSOCIA TED WITH DESIGN ENGINEERING Al :10 CFR Part 30. Appendix B. Criterion 111. " Design Control." requires, in part, that measures shall be

' estabhshed to assere that opphcable design bases are correctly translated into speci6 canons.

drawings, precedures, andinstructions.

1. Contrary to the above, on June 1,1994, the design bases were not correctly translated into

- operanng procedures regardmg switchover of the decay heat removal system (DHR.D pumps.

from the barated water storage tank (Bif 3T) to the reactor building sump. Nonconservatnv assumptions and input data, such as operator response times. valve stroke times, instrument errorsfor the Bil3T low-low level alarm setpoint. containment pressure, and Input datafor estimatmg vortex depth uere used in calculanon C-1101-212 5310-030. "Thi11 BIf 3T l'orter Determinaticn." This calesdation provided the Bif3T level setpomt spec { Red in abnormal transient and alarm response proceduresfor commencing manual operations to switchover the suction qf the DHRS pumps from the BII3T to the reactor buildmg sump durmg a large break

. loss ofcoolant accident (LOCA). The BIf3Tlevel setpoint determmed in the switchoverphase design colculanons may not haw prevented air entramment in the DHRS pumps and the reactor buildmg spray (RBS) pumps, due to vortexmg m the BIf 3T. This could have resulted m air biruimg and'or cavitation nithe DHRS pumps and rise RBS pumps causmg them to be t'wperable durmg the critical recirculation phase qfa large break LOCA (0/013)

2. Contrary to the abow, as ofJanuary 10. I997. design bases were not correctly translated into operatmg procedures in that the calcidations that support the makeup tant pressuredevel hmit curves tn Ibese procedares were based on mcorrect inputs. Specifically:

a. Caletdation C-Il012il-3310-0047 Revision 0. did not include a section of the makeup pump suction paping andfittings. used nonconsermttve values for maximum

. high presiure injectionflow rates, and did not consider the efects qfwrtexmg.

b.- Calculation C Il01-2115360-003. Revision !. did not consider a conservative high pressure mjection flow when the reactor pressure is O psig during loss qf coolant accidents.

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, a ATTACllMENT 1 6710 97 2483 Page 2 of 31 1he use of the inaccurate makeup rank pressure hmit curves during operation of the high pressure uniection pumps qfer a high pressure Injection ime break could have caused the immps to operate under degraded net posttive sucnon head conditions, (01023)

H 10 CFR part 50, Append;: B, Crtienon 111, states, m part. that the desig,o control msasures shall providefoe wr6ing or checking he adeq.tacy qfdesign.

1. Contrary to the abow, as of Januoy 10, 1997 field sketches comumed in engmeermg cwluanon request (EER) 88-370-E v re not verthedfor use by engineenng in an ewluation re.,aestfor incorporating s tatic head correenon in the cahbration ofa Bil'ST level switch The sketches had no drawing numbers assigned, did not show plant elemtions or survey marks, and had no documentation that they had been revacu ed or approved. (0/033)

2. - Contrary to the above. between July 1988 and January 1996, sqfety-related calctdations were perf>rmed m memoranda. Te.hnical Data Requests (TDRs), and EERs that were not ver{ Bed or approved as evidenced by the fcilowmg examples cach of uh:ch constitutes a separate violanon:

a hiemorandum $310-92 024. "DH l'-14A:B, DH-l'5A B, BS l'-52A B l'alves and IST Program." dated A' arch 1 I994, incorporated a calculation to omit leak testing of >

check whvs DN-l'14A and DH l'l4B as part of the inservice testmg (157) program.

An incorrect wluepr reactor buildmg (RB) pressure was used m the calendation. As a resuh, the analysis met rrectly conchided that these wives did not perprm a sqfety pnction m the closedposition. Consequently, testing ofDH-l'14A and B m the closed postnen uas not mchaded m the ISTprogram, contrary to Technical Spec {fication 1.2J uhich requires testmg of sqfety-related wives in accordance with 10 CFR 50.55a and Secnon XI of the Amencan Society ofAfechamcal Engineers and Pressure l'essel Code.

(10143) h Afemorandum $310 92-366, "Ewheatmn qf Thl' ! NPI SSFI Observation No. 211-10 "

dated December 22, I992, incorporated a enhulation to reschv a concern from GPUh"s sqfety system pnctional inspection (SSFI) qf the makeup and punhcanon (AfU&P) system reganhng dead headmg of makeup pumps under wrtous combmations ofoperatingpumps. (10153)

-- c. TDR No. 836. Revtston 6, datedJanuary 31,1995. contained a sqfety-related analysis pr "Emluation for Loadmg of II.e Emergency thesel Generator and Engmeered Safeguards (ES) Buses. "(10163) d TDR No 995. Revision 3. "l'oltage Drop Studypr Degraded Gnd Condmon." dated January 18. 1996, comained sqkry-related electrical system design calculanons.

(10173)

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c. EERs 88 060-E, ."BH37 f.ew! Alarm Setpoint Change." dated July 29,1988; and 88 070-E, "Cahbration ofDH-DPS 91't." dated August 10. ]988, contamed safety-related setpoint correction calculatwnsfor spectfic gravan'. (10183)

- These memoranda. TDRs, and EERs ucre not wrified or approved in order to check the adequacy ofthe design.

C. 10 CFR $0.39 states, un part, that changes in thefacihty as described in the safety analysts report may.

v be: made without pnor Commission approwl, unless the change mvohes an unrevieued sqfety question 'A change shall be deemed to im'olve an unreviewed safco' question; in part. If the probabihty of malfunction of equipment important to safety previously emhiated in the sakty.

emluation report may be increased i Contrary to the above. on Febnuny 20.1990, a change that Inmlwd an unreviewed safco' question uas made u;ithout prior Commission approwl. Spscifcally, the sod'um thtosultate tank was removed and the BH3T low-low level alarm setpoint was changed which c rused the calcidated post-accident reactor buildmg sump water level at the time of switchover to .ecuculatwn to decrease. Wtth the reduced sump level, the amilable net positive suction head (NPSH)jbr the DHRSpumps uas less than the required NPSH with Indicated low pressure injection (12'l) flow of 3300 gym unless credit was takenfor containment overpressure. Updated Fmal Safco' Analysis Report (UFSAR) Sectwn 6A.2 was revised to Indicate that credit was taken for containment owrpressure in determinmg that sufficient NPSH would be amtlable Jhr the maxtmum 12iflows: This was contrary to the origine' safety emluation which did not consider containment overpressure in the NPSH emluation. Without taking creditfor containment overpressure the requtred NPSH might not be available during an accident ar' the probability ofmaltimction qf the DHRSpumps r say be mcreased Therefore, an unreviewed scry question was inwhsd (0/093)

These violanons in Sectwn I represent a Sewrin' l.crel ill problem (Supplement 1). Ctvil Penalty -

S50.000.

GPUN RESPONSE TO VIOLATIONS IN SECTION I BACKGROUND A_ design team inspection was performed at TM1 1 by the Special Inspection Branch of Nuclear Reactor Regulation (NRR) and its contractor Stone & Webster Engincering Corporation (SWEC) during the period November 12,1996 through January 10,1997 The inspection team performed a comprehensive, in-depth examinat:on of the design and licensing basis documentation for the Makeup and Purification (MU&P) and

. Decay Heat Removal (DHR) Systems. The MURP System includes high pressure injection (HPI) and the -

_ DHR System includes low pressure injection (LPI). A public exit meeting was held at TMl on Januarp 30,

1997; By letter dated April 15,1997 NRC provided Inspection Report (IR)96-201, "Three Mile Island - Unit 1, Design Ir.spection? The cover letter stated that the team noted that the design documents for the reviewed

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ATTACllMENT 1 J 6710-97 2483  ;

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systems appropriately implemented the intent of the design and licensing basis except for the specific cases .

!~ identified in the report. Appendix A of the report listed the open items (Ols). In response to the inspection report, GPU Nuclear provided an update including a current status and schedule for completion of actions -

- to resolve the remaining Ols in a letter dated June 23,1997. A resised schedule for five of the Ols was submitted to the NRC on December i1,1997.

"Ihe NRC's letter of April 25.1997 identified those open items from IR 96-201 that were considered -

4 potential siolations slated for discussion in a predecisional enforcement conference. During the conference which was held on May 22,1997, GPU Nuclear agreed with the NRC's assessment of many of r.hc issues : ,

. that were raised, prosided additional perspective on the issues raised in the report and related swne of the -

. important actions planned to prevent a recurrence of those findings including: the implementation of a new process based engineering organization, development of a new self assessment program, and the initiation of a new corrective action process (CAP), as well as many of the actions that are being taken to address the specific findings in IR 96 201, GPliN RESPONSE TO VIOLATION 1.A.1 GPtf Nuclear anrees with the violation.

Erason for the Violation The reason for this violation was incorrect engineering judgement in that the combination of events necessary to attain the most conservative RB pressure conditions for this analysis were not identified during the calculation review process.

Corrective Steps Taken and Results Achip34

1. A BWST drawdown analysis was completed which models the revised operator actions specified in item 2 and demonstrates the completion of switchover to the RB Sump recirculation leaving margin above the minimum BWST level where air entrainment may begin to occur.

2. Procedure changes were implemented to instruct the operators to open the RB sump recirculation valves and to close the Borated Water Storage Tank (BWST) isolation valves consistent with the assumptions used in the revised analpis.

3.  !!or additional actions taken, see LER 96-002-0l, dated D'e cember 11,1997.

Corrective Steps to be Taken to Avoid Further Violations Improvements related to the calculation process are discussed in response to Violation 1.B.2 below.

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ATTACith1ENT.1 6710-97 2183

- Page 5 of 31 Date when Full Comoliance will be Achieved Full compliance has been achieved ,

GPliN RESPONSE TO VIOI ATION l.A 7

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GPll Nuclear antrees with the violation Beason for ths Violation The reason for the violation was the use of non-conservative design inputs, as described in a. and b. below that were not identified through the design verification process:

a. Calculation C 1101 211 5310-047, Revision 0. 1) Omitted a section of the makeup pump suction piping and fittings because a secondary source document was used rather than the primary reference for the design input,

2) Used non-conservative values for maximum HPI flow rates for drawdown from the hiakeup Tank based on the conventional design practice to maximize flow during drawdown from the BWST, and 3) Vortexing was not addressed in the calculation.

b. Calculation C-11012115360 003, Revision 1, did not considee conservative makeup flow with 0 psig backpressure. The analysis had postulated a crack rather than a break for this scenario and a 1600 psig

. backpressure was used rather than a O psig backpressure for a break on the normal MU line. Since the scenario ends upon ES actuation (at 1600 psig RCS pressure), this may have men the reason that 1600 psig was used as the backpressure for the analysis.

" Corrective Steps Taken and Results Achieved I. Calculations Cl101211-5310-047, " Makeup Tank Drawdown During LOCA,"and Cl101-211-5360-003, .

" Makeup Pump NPSH" have been superseded by a new calculation, C-1101-211-E610-066. " Makeup Tank Level and Pressure Limits " The new calculation accounts for'a lower backpressure, procedural limitations to flow, and correction of other non-conservative assumptions referred to in the violation except for vortexing.

2. Operating Procedure (OP) I 104-2, " Makeup & Purification System " and Abnormal Transient Procedure (ATP) 1210-01 " Reactor Trip," were revised consistent with the new analysis.

- 3. Recent efforts to improse the engineering calculation and design verification process include training, which emphasized the questioning of references during the design verification process.

L 4. Programmatic improvements in the calculation preparation and control processes are addressed in response to Violation I.B 2.

Corrective Steps to be Taken to Avoid Further Violatio.n.3 n Analysis to address the potential for vortex formation in the Makeup Tank was overlooked when calculation Cl101-211-E610 066 was prepared to replace the two calculations named m the violation above. GPU Nuclear 1will complete this additional analysis by August 1998.

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- pate when Full Compliance will be Achieved Full compliance will be achieved by August 1998.

GPUN RESPONSE TO VIOLATION I.8,1 GPU Nuclear nerees with the violation.

Recson for the Violat).2n The proper head correction was measured for DH.LT-0808 and Dl-1 LT-0809. Field sketches included as

= part of Engineering Evaluation Request (EER) 88-070-E and EER 88-060-E show the measured head -

correction. The head correction information used in surveillance procedure 1302-5.19 was obtain-d from these engineering evaluations. While the EERs were reviewed and approved, the field sketches prepared as part of the EER were not incorporated into design documents which receive a separate design verification or design check.

Corrective Steos Takenynd Results Achieved Tasks were initiated during the inspection to track completion of the update documentation related to DH-LT-0808 and DH LT-0809 includmg:

1. Drawings 308810 and 308920 were updated by Engineering Change Document (ECD) 211112 to show the transmitter and BWST elevations. This provides the basis for the head correction for each transmitter.

2. The GMS2 database was updated to reference the change document, which changed drawings 308910 and 308920.

3. SP 1302 5,19. " Borated Water Storage Tank Level Indicator," was changed in Revision 19 on February 5,1997 to reference the drawings 308910 and 308920.

1, A new loop error ca:culation. C-1101 212-E510-057, "TMI BWST Level Loop Accuracy." was issued for the BWST level instrument loops that references the revised P&lD drawings for the appropriate head correction.

Corrective Steps in be Taken to Avoid Further Violations in order to assure that any potentially similar problems with other process measurements and setpoints are '

' addressed, plans for a setpoint basis update program was initiated in response to the NRC's 50.54(f) letter

. of October 9,1996 This program will provide a database for reference to the design basis document (i.e.

setpoint calculation) for each setpoint reqmred to operate the plant within its design bases. If a setpoint basis document can not be found, an engineering task will be initiated to have the setpoint basis established

Once a setpoint basis document is establi'shed. the document will be referenced in the setpoint program

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'  : database as a source document, His program will ensure that design setpoint references are captured and casily retrievabic. The program will also ensure that EERs which involve setpoints will receive a design

- verification that will check design inputs such as the above mentioned design drawings,308910 and 308920; Date when Full Compliance will be Achieved

. Full compliance has been achieved He setpoint update program will be completed by February 1999.

GPtIN RESPONSE TO VIOL,ATION 1.B.2.a. 2,b. 2.c. 2.d. and 2.e ,

i GPli Nuclear merces with the violation.

Reason for the ViolatLou The specific examples cited in the violation raised concerns with calculation control and caused GPU Nuclear to do a more thorough review of the existing process and implement changes as a result of these

. findings.

A root cause evaluation was performed to address problems that were cited with the control of calculations.

This evaluation extended beyond the specific issues identi6cd in the violation.- The root causes listed below pertain to issues identified in the violation which describes the performance of calculations in documents that were not verified or approsed in order to ensure the adequacy of design. The causes of this condition hase been identified as follows:

I - Lack of familianty/ inadequate training on the requirements of the procedures.

2. Personnel error on the part of the individual contributor to perform work in accordance with procedures.

3. Lack of management enforcement to fully implement procedural requirements Each of these causes and other causes associated with problems found in the overall calculation process have been reviewed and analyzed. As a result, a number of activities are in progress or have been completed to address each root cause.

Corrective Stein Taken and Results Achieved:

GPU Nuclear has revised procedures and trained personnel to ensure that safety related calculations are only performed in accordance with procedurally specified methods to ensure compliance with 10CFR$0 Appendix B.

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ATTACilMENT 1 6710 97 2483 Page 8 of 31

1. . A root cause evaluation of the deficiencies identified with the control of calculations was performed.

ne results were documented in a memorandum dated June 13,1997.

2l Immediate training was performed for the enFi rcring stafTto reinforce the procedural requirements for the performance of calculations in February 1997.

3. A new calculation process was implemented with the issuance of procedure EP-006, " Calculations",

Revision 5, which became effective on September 5,1997. This procedure revision addressed those procedure-related root causes that were identified during our review of the calculation process issues.

Formal training on the new procedure revision was completed in November 1997.

4. In a May 16.1997 memorandum (via electronic medium) to all engineering personnel, the Vice President, Engineering stressed that Engincenng personnel must understand and comply with procedures and reminded them that if a procedure (s) cannot be followed, one should stop work and discuss this with their supervisor. The memorandum stated that it is essential that review of the design basis information be thorough and complete and that one not allow sche 'ules. or other pressure to cause one to take short cuts.

5. He specine examples cited in the violation have been addressed as follows:

a Dil V-14A/B, Dil-V 5A/B, BS-V 52A/B were incomorated into the Inservice Testing (IST)

Program and tested durinc the Cycle 12 Refueling (12R) Outage that was recently completed.

b. A calculation found in Memorandum 5310-92 366," Evaluation of TMI I IIPI SSFI Observation No. 211-10," dated December 22,1992 is scheduled to be incorporated into a verified calculation in accordance with the revised calculation process by December 31,1997. That memorandum was prepared to resche a concern from the safety system functional inspection (SSFI) on the makeup and purification (MU&P) system regarding dead headmg of makeup pumps under various combinations of cperation pumps.

c. A fonnal calculation is being prepared to replace Technical Data Report (TDR) No. 836, which contained a safety related analysis for " Evaluation for Loading of the Emergency Diesel Generator and Engineered Safeguards (ES) Buses." That calculation is scheduled for completion by September 30,1998.

d. A fonnal calculation is being prepared to replace TDR No. 995, " Voltage Drop Study for Degraded Grid Condition." dated January 18.1996. That calculation is scheduled for completion by September 30.1998.

c. Calculation C l 101 212-E510-057, "TMI BWST Level Loop Accuracy," has been completed to incorporar: Engineering Evaluation Requests (EERs) 88-060-E, "BWST Level Alarm Setpoint Change," dated July J.1988 and 88-070-E, Calibration of DH-DPS-914, dated August 10,1988.

6. Further actions taken include.the fohswing:

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a. The review to identify design basis calculations for key design basis parameters or safety system functional requirements of high safety signi6cance was completed as documented in a June 27,  !

1997 memorandum. l

b. An assessment of calculation procedure compliance through a sampling of memoranda, TDRs, and i Topical Reports (TRs) was perfonned as documented in the June 27,1997 memorandum. Non-compliances identified as a result of this assessment are documented in an October 24,1997 memorandum. These deficiencies are being processed and tracked by corrective action processes in accordance with the GPU Nuclear Operational Quality. Assuranet Plan - Quality Deficiency reports (QDRs) or the Corrective Action Program (CAP).

The revised calculation process, its implementation in Revision 5 of Ep-006 and the training provided to

- the engineering staff have strengthened GPU Nuclear's understanding of and compliance with the requirements for design control related to the control of engineering calculations.

Corrective Steps to be Taken to Avoid Further Violations:

The assessment of compliance voith the calculation process has identified other non-compliances in memoranda, Technical Data Reports (TDRs), and Topical Reports (TRs) that were found to contain calculations performed outside of approved procedures. All identified non-compliances will be corrected by December 31,1998.

Included in our assessment are the no..-compliances cited in example b of the iolation, which is scheduled to be completed by December 31,1997, and those cited in examples e and d of'he violation, which are scheduled to be compic:cd by Septcmber 30,1998.

Date when Full Compliance will be Achieved:

Full compliance will be achieved by 12/31/98.

GPUN RESPONSE TO VIOL.ATION I.C GPU Nuclear merees with the violation Reason for the Violation

- The root cause of this violation is the non-conservative approach utilized in the application of original

- licensing basis criteria and parameters to the plant change being implemented and evaluated under 10 CFR 50.59c GPU Nuclear Safety Evaluation No. I15403 004, Revision 0, which supponed the UFSAR Section 6.4.2 revision, incorrectly conside:ed that the assumption of no credit for containment overpressure abos e the sump vapor pressure only applied to the original licensing basis accioent analysis condition of 3000 gpm Low Pressure Injection (LPI) flow rate and 1500 gpm Reactor Building Spray (BS) flow rate, and adequate NPSli was demonstrated at these conditions. The procedurally Innited How rate of 3300 gpm represented pur unout conditions and was considered to be beyond the licensing basis as presently defined by the TMI l FSAR and NRC Safety Evaluation Report (SER) dated July 11,1973 for TMI-1.

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Since this condition was interpreted as being beyond the licensing basis, it was determined that use of conservative but more realistic assumptions in terms of containment overpressure was acceptable. ,

instrument ertor was not assumed in the analysis for the procedurally ht.iited now rate of 3300 gpm  !

4 because the original licensing NRC (SER) dated July 11,1973 for Thti.! had only addressed the accident .

analysis LPI How rate of 3000 gpm with no consideration ofinstrument accuracy.

Corrective Stens Taken and Results Achieved i

GPU Nuclear has implemented revisions to Abnormal Transient Procedure (ATP) 1210 07,"Large Break LOCA Cooldown", to limit LPl and BS How rates to ensure that these pumps are operated imder conditions where adequate NPSil is available without enadit for containment overpressure OPU Nuclear

~ Safety Evaluation No. 000212-032 and associated analyses supporting this procedure change have ensured that system safety functions and licensing basis requirements are maintained

- This corrective actmn has restored the existing licensing basis, which did not consider containment i

overpressure above the vapor pressure of the sump liquid in the NPSil evaluation.

Additionally, OPU Nucleai issued an internal Safety Review Newsletter in June 1997, as part of the GPU ,

Nucicair Safety Review Process Program that included a review of the lessons learned from this issue.

Corrective Stens to be Taken to Avold Further Violations The Thil 1 Updated Final Safety Analysis Report (UFS AR) will be revised in the next scheduled update (Update 14 - April 1998) to remove the existing description of the NPSit calculation for BS and LPI pump  ;

maximum Dows which credits containment overpressure, Additionally, FSAR updates have been issued and will be included m Th11 1 UFS AR Update 14 to identify the LPI and ils pump NPSit requirements ,

includmg the design basis assumption in tie NI Sil evaluation that there is no credit for containment ,

pressure above the vapor pressure of the sump liquid. This is consistent with the NRC SER dated July 11.

' 1973 for Thti l.

pate when Full comoliance willite Arhieved Full compliance was achiesed on June 28,1997, when ATP 1110-07 was revised to limit BS and LPl flow . 1 rates such that the NPSil required was satisfied with no credit for containment overpressure. l Section ll. I701.A110NS ASSOCIAlliD lt'!1H liOUlPMl?NTIX)ll'NGRAD1?S A 10 CFIUOR "t 'hanges, tests and expenments " permits the hcensee. m ture. to male changes to the  :

facthty as desenbed a the sakt;, analysts report without pnor Commisswn approwl pronded the change does not snadve an wtrencued sakty question (USQL 1hc hcensee shall mamlatn recnnts of changes m thepcthly ana these records must mchtde a untren safety eval; ation uhich prondes the _

basesfor the determmatwn that the change does not mwhv a USQ 1

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4 ATTACllMENT I 6710 97 2483 Page 1I of 31 Contrary to the abcnv. betueen September.1992, and December,1994, the bcensee made changes to Joungrade the quahty classthcation qf components and systems descrtbed in the UIMR utthout ,

performing a u nnen safety enduation for the mqjority qf these changes to pnwide the basts for the determma: ton that the changes did not snwhv a USQ. It'ah regard to nuclear safety related component quahty. section 12.31.2 of the UIMR states, "Afaterials and parts utthred in the repaar and masntenance of the nuclear relatedportions qf the umt will he qf the same quahty as, or bener [

than, the ortgenal materials " Thefacthty uas changed by excludmg the component quahty assurance (QA) program requirements for the maintenance, tesnng. cahbration, receipt inspectron and procurement qfpartsfor thefolloutng components cach qf which consntutes an Indn1 dual violanon.

without performing a wntren safety cwhtationfor any of the changes.

L 1hc quahty classthcanon checkhsts (QCLs)for the nuclear rhvr (NR) uater motor operator discharge vahrs NR lilA'lB&lC were revned on July 18. 1994 to doungrade the ,

compcmentsfrom nuclear sqfety related(NSR) to a non safety related classtneation. The vahr operator is required to matntain NR sysicm operabthlyfor postulated accident conditions as required by Technical Spectheation sectmn 3J L 4 and as desenbcd In UIMR section 9 62.3 (020I3)

2. The QCLs for the decay rtect (DK) water stramer motors DR S lA&lB ucre rn*tsed on July

18. I994, to downgrade the componentsfrom NSR to a non safety related classt6 cation. The stramer is designed to automatically operate to mamtain DR system operabthty as required by TechnicalSpectBcation section 3J L 4 andas descrtbed on UI.MR secnon 9A2. (02023)  ;

3 The QCLsfor the anxthary butidmg ventdation system (ABl'S)):ms, Jan motors. IlEPA fibers.

flow transmtucts and other componems u cre revtsed on November 10 and December 22.1994.

to doungrade the componentsfrom regulatory required (RS) to "other" a non-safety related class!ncanon 1hc *ystem is desagned to mamtam the Auxthary Butidmg at a negatnv pressure to prechtde the relcase qfradwactnv material, and mitigate the consequences of the postulated waste gas tank ntpture and martmum hypothencal accident as desenbcd m the UIMR secnons 9.8.3. I4.2.2.5. and 14.2.2h (02033) .

4. The QCLs for the whv operator and postnaner for make-up (AfU) why AfU ILl7 ucre revised on Afarch 18. I991 to downgrade the whv components from NSR to lut The QCLs for the whv operator and posanonerpr AfU l%I7 were revised on November 9,1994, to downgrade the whv componentsfrom RR to "other", a non-safety related classthcation. The QCLpr the regulatorpr AfU l'.17 uas revised in September 1992, to doungrade the whv componentfrom NSR to RR. Ihc QCLfor the regulatorpr AfU lL17 uas revtsed on February L 1994, to downgrade the whv component fro n RR to "other". a non-sakty related classt6 canon AfU lil7 pnwides a safetyfumetwn to isolate the normal reactor coolant system (RCS) AfU hne dunng a postulated small break LOCA to ensure adequate core coohng as descnbcdIn UIMR section 61.3 L (02043)

B Technical Spectneanon 6.3 L 1 requares, in part, that each procedure u htch alkets nuclear sakty. and

- substantur changes thereto, be prepa ed by a awy:md mdwidual(s)' group knowledgeable m the area afkcted by the procedure. Each procedure, and substantur changes thereto, shall be re.'icu ed

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ATTACHMENT I 6710-97 2483 Page 12 of 31 for adequacy by an Indtvidual(s) group other than the preparer, but who may be from the same

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organization as the Individual u ho pretured the procedure or change.

14 chnical Specthcation 6 3.1.12 requires. In part. that mdividuals responsiblefor revreu s performed In accordance wnh 1\ chnical Specthcatton (TS) 6.3.1.1 render determinations m writmg wnh regard to u hether or not a change to a procedure uluch a,(kcts nuclear sqfety, as noted in 6.31.1, constnutes a USQ Contrary to the abm e, on J>me 16. I993. Technicalinmctions Division procedure EP-01L "Afelinulology For Prepartng The Quahty ClasstAcation last. " Revision 4. a procedure u htch a[kcts nuclear safety, was revised and no safety enduanon was performed to determine that the change did not inwhv a USQ. (02033)

C. 10 CFR Part 30. Apperuhx H Cruerton l'. "Instnicnons. Procedures, and Drautngs" requires that actinnes afketing quahty be prescribed by documented tr.struenons. or procedures pf a type apprornate to the circumstances and be accomphshed m accordance with these instnictions, or proccJures.

Technical inmenons Division procedure EP-OlL Rev. t. "Alethodology for Prepanng the Quahty ClasstAratton Last (QCL)," provides Instructions for performance qf the component classancation.

don ngrade, and upgrade processes, an acnyny q[Rcting quahty.

1. Section 2.2 qf EP 01I states: "This procedure is apphcable to hardware only and not acuvines, as detailed m paragraphs 2.1 and 2.2 qf the Operatmnal Quahty Assurance (0QA)

Plan " The OQA plan de(mes, m part, activnics as mamtenance. cahbration and testmg Contrary to the above, beturen the penod qf December 1990 through February 1996, sqfety related QCL acnnti. s u cre not accomphshed in accordance wnh section 2.2 ofEP-01I m that several QCL checkhsts ucre rensed and contamed changes to component acnntres such as mamtenance, cahbration. and testmg (02063)

2. Section 3 I qfEP-01I tequires that QCL norksheets and checkhsts be prepared in accordance uith Ihhtbn 2 ofEP-011. Ihhtbu 2 qfEP-01I requires that the critena in Exhibit 3 qfEP-01I be used to determine thefuncnonal class (class 16 cation) ofcomiuments.  :

Contrary to the above. between the penod qf December 1990 through 1+bruary 1996. sqfety related QCL acnntics u cre not accomphshed on accordance wnh secnon 3.1 and thhtbit 2 of EP-01I in that the criteria in Exhtbit 3 were not used ta determme thefunctmnal class qfsome NSR and RR compcments. As a resuh, components u cre imyroperly Jou ngraded (02073) 1hese wolations in Section il represent a Seventy Level ill problem (Supplement 1). Cint Penahy -

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ATfACilNiENT I 6710 97 2483 Page 13 of 31 GPilN RESPONSE TO VIOI ATIONS IN SECTION II IIACKGHOUND During inspections of engineering processes at Three hiile Island (TMI) in January and February 1997, the NRC raised concerns regardmg the GPU Nuclear Quality Classification List (QCL). The NRC concerns tclatal to primarily four areas: (1) Procedure siolations. (2) Downgrading of quahty classi6 cations without appropriate safety reviews, (3) Safety Review Process not applied to certain Engineering procedures, and (4) Inclicctive corrective action process.

As a result of the NRC concerns, GPU Nuclear committed to stop the programmatic equipment classi6 cation downgrade process at TMI l and Oyster Creek, and to detennine the potential impact of inappropriate downgrades immediate actions were taken to stop the QCL downgrade process, revise the QCL procedural guidance and detennine the impact ofinappropriate downgrades The GPU Nuclear Apnl 30,1997, letters to the NRC on Oyster Creek and TMI l desenbe these actions.

GPU Nuclear also conimitted to perform an assessment of the quahty classi6 cation process (referred to herein as the "QCL process"), in order to determine the root causes of both the process weaknesses and the failures to properly address Quahty Assurance (QA) findings in this area, and to make recommendations for correctne action by July 1,1997. Additionally, GPU Nuclear agreed to detennine if other engineering processes are subject to the same problems and to determine what changes to the engineering processes are necessary based on the results of this assessment The NRC issued Con 6rmatory Action Letter (CAL) 1 97-008 to GPU Nuclear on March 4,1497, documentmg their requested actions and the GPU Nuclear commitments On March 14.1997. GPU Nuclear semor management established the Engineering and Correctisc Action Process Assessment Team (ECAPAT) to perform the subject assessments. The ECAPAT was established as an independent group. chaired by and comprised primanly of outside, senior industry esperts. Also included on the ECAPAT were selected senior GPU Nuclear management representatives to facilitate understandmg and ownership of corrective actions recommended by the ECAPAT, as well as a GPU Nuclear root cause analysis pracutioner.

Dunng the penod from March through June 1997, the ECAPAT reviewed related correspondence and historical reports, received presentations on the QCL process. engmeenng programs and other processes, and interviewed line management, senior GPU Nuclear management, oversight / Nuclear Safety Assessment (NS A) and engineenng personnel and Oy ster Creek and TMI QCL process practitioners.

The ECAPAT exanuned the GPU Nuclear QCL process and the problems related to classification downgrades by studying four distinct (but related) areas: the adequacy of the QCL process and procedures, the QCL process implementation. oversight effectiseness, and correctis e action effectis eness in cach case, the ECAPAT noted speci6c observations (errors, problems, weaknesses, etc.), deternuned their apparent causal factors and underlymg (root) causes. and fonnulated recommendations accordmgh .

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ATTACliMENT I l 6710 97 2483 Page 14 of 31 l As reported in a July 16.1997 meeting with NRC Region I managuent, the ECAPAT iden'ified numerous  !

weaknesses and associated causes that are interrelated. In aggiegate, the ECAPAT concluded that the j central root causes of the GPU Nuclear QCL proecss problems were as follows: j

1) GPU Nuclear management failed to establish. communicate and enforce expectat ans for the QCL pnicess implementation

2) GPU Nuclear management did not apply sufficient emphasis and attention to QCL program oversight and corrective action activities

3) GPU Nuclear management did not adequately plan, prioritize and support QCL program activities to ensure appropriate application oflimited resources to multiple tasks.

GPUN RESPONSE TO VIOLATIONS li.A.I. A.2. A.3. and A.4 l GPil Nuclear anrecs with the violation. .

Ruson for the Violation B

Engineering Procedure EP Ol l," Methodology for Preparing the Quality Classification List," established

• tim method to assign quality classifications to structures, system: and components. EP-011 did not contain '

provisions for the perfonnance of safety determinations, and safety evaluations if required, when equipment classifications were downgraded. It was not recognized that 10 CFR 50.59 requirements had to be satisfied for QCL downgrades. De process design did not account for the possibility that qual ty classification .

changes would be made independent of the modification process. A small number of safety evaluations ,

were performed for classification changes made at the system level, and for some component level changes when it uas believed that the change was significant. Ilowever, decisions to perfonn safety determinations and safety evaluations for equipment classification downgrades were inconsistent.  ;

Corrective Steps that llave Been Taken and Results Achieved ,

GPU Nuclear halted further downgrades. Incorrectly downgraded equipment was retumed to its previous classification, All programmatic downgrades have been reviewed and safety detenninations/ safety evaluations have been perfonned EP-01I was revised on April 29,1997, and training was provided to all personnel imched with the QCL process. The procedure was added to the safety review program and a safety evaluation documented the bases for the revision. The revised Ep 01I has fonnalized the QCL process and included written detailed standards related to component and program changes. EP-011 now requires a written safety determinatiorvsafety evaluation when Se quality classification of a component is changed from a higher to a lower classification. These changes provide reasonable assurance that 10 CFR ,

50.59 requirements will be met when equipment downgrades are perfomied  !

Date when Full Compliance will be Arhieved Full compliance was achieved by May 21,1997. GPUN plans no further action on these violations.

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t ATfACllMENT 1 l 6710-97 2483 j Page 15 of 31 GPllN RESPONSE TO VIOL. ATlON li.B }

GPtl Nuclear anrees with the violation.

Hgason for the Violation ,

GPU Nuclear failed to recognize that EP.-01I was subject to the safety review program in accordance with cited Technical Specifications. The cause of this condition was not consistently implementing and/or interpreting the requirements of our Safety Review Process.

.C2Itsetive Stens Taken and Results Achieved Engineering procedure EP 011, Revision 5 was generated and received a safety review prior to issuance l Corrective Stens to be Taken to Avoid Further Violations To assure other Engineering procedures comply with the safety review process, Quality Deficiency Report (QDR) 971012 has been issued.

Date when Full Compliance will be Achieved Full compliance has been achieved with issuance of Revision 5 of EP 011, All Engineering procedures will receive a safety review by January 31,1998.

GPilN RESPONSE TO VIOI.ATION ll.C.1 and C.2 GPti Nuclear anrecs with the violation.

Bra 3on for the Violation There was a lack of clarity in EP-011. Revision 4. There was a lack of discipline to follow EP 011, Revision 4, This procedure was not effectively reviewed and tested before full scale implementation, and generally did not have 6cid " buy-in," Management expectations and guidance were insulticiently communicated Corrective Steps Taken and Results Achieved EP 011 has been revised and training was provided to all engineering personnel involved with the QCL processi Changes include the following: (1) safety reviews are now required for all downgrades, (2) operabihty reviews are explicitly required for upgrades to NSR, (3) enhanced functional and failure criteria were added to the classi6 cation process. (4) enhanced Regulatory Required (RR) criteria have been added, and (5) the applicability of the procedure was changed to reDect the intent of the program quahty controls.

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ATTACllMENT I 6710-97 2483 Page 16 of 3i Corrective Stens to be Taken to Avoid Further Violations l All engineering division personnel will receive training on management expectations regarding accamtability to comply with procedures.

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'A new engineering procedure " Conduct of Engineering," will be issued. This new procedure will establish

. i and communicate management expectations regarding accountabihty to comply with procedures.

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Thw Seneral Employee Training program and Engineering Support Personnel Training program will be i revised to incorporate management expectations regarding procedure compliance.

- 'the Quality Classification Process will be evaluated for completeness, integration with other procedures and processes, and for overall adequacy. Following this " mapping" of the Quality Classification Process.

perfbrmance indicators will be developed and performance trending of the QCL process will be perfonned Date when Full Comoliance will be Achieved Full compliance has been achieved. The additional corrective action will be completed by April 30,1998.

Section HI l70LA 770NS ASSOCIA 77?D ll'ITH INADliOUA 77i CORRiiCTIVli AC170NS 10 CFR Part 30. Appendix B, Crtterson XI7. "Correenvc Actions." states, in part, that measures shall be estabhshed to assure that conditions adverse to quahty such as fathorcs, malhmettons, dcBetencies, deviations, defecure material aniequtpment and nonconformances are promptly identsRed and corrected in the case qfsign:Reant condinons adverse to quahty, the measures shall assure that the cause of the condition is determined and correctnr actton taken to prechtde icpetition.

A Contrary to the abmr, as of I)cccmber 2.1V96, a condition adverse to quahty.

sdentthed by GPUN durmy the safety systemfunctional inspecnon (SSFI) of the decay heat remomi system in 1992. had not been promptly corrected S >ectfocally. MFI Obscimnon 212 42 ident{ fled that the 1) HRS pump vent whrs were not mchtded in the environmental quahBcatton (EQ) program. As qf Ocwb:r 20.1992. GPUN had determmed that the DHRS pump vent whrs had a safetyfimction, and therefore, should have been inchtded in the EQ program. Howervr. as qf Dccember 2.1996.

these whrs u ere not mcluded in the EQ program. - (030/3)

Il Contrary to the abmr, betueen June 1.1992, and March 2.1997, identified deficiencies In the supportmg documentation for the safety classification qf compcments were not promptly corrected: Spectfically:

- in audit report 0-COM 911.t. finshng 1. dated June 1. I492 the hcensee identalled that procedure EP-0)l or the Quahty Classtncation List norksheet dad not always provide surlictent detads to support the classification qfnems

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! Page 17 of 31 without recourse to the originator. This significant condonon adstrse to }

quahty uas not corrected untii Afay 23. I993, i i

. In audit report 0-COAL 93-0V, findtng 12, dated December 21,1993. the l hcensee identificd that EP-Oli did not steline how to prepare a revision to a Quahty Classalication List Checkhst and did not require that the bases for  :

- revisions be documented so those other than the Quality Classthcatwn List  :

engineer who prepared the change could undentand the basis of the change. ,

This stgntficant condinon adverse to quahty was not corrected as qfAfarch 2.

1997.

. In the Independent Safety Review (ISR) qf audit n' port 0-COAf 93 09, ,

initiated on Afay 16. 1996, the independent Safety Reviewer identtRed the concern that changing the quahty classthcation of components without documented or apprmvd basis. mdependent review, and wnhout a wnnen  ;

safety evahuation documennng the basts of the change may be a violanon qf10 CFR 30.39. Yhts signtRcant condstwn adverse to quahty was not corrected as ofAfarch 2, l997.

The corrective actionsfor thefindmgs qf 0-C0Al 9113 were snellective in that they did not preclude repettlion qf the problem ofInsuficient documentation to support the QCL activittes. (03023) ,

C Contrary to the above,from Afarch 21, )997 unni April 24,1997, the bcenseefittled to take prompt and adequate correcnve action for a conshtton adverse to quahty.

SpectReally on Afarch 21. 1997, the hcensee identificd that reactor buildmg emergency coohng fim. AH.E lA was not environmentally quahlied, in that the opphcation qf heat shrink tubmg left a small length of exposed conductor at the spark phtg connector to thefan motor. True hcenseepiled to conduct suficient additional' reviews to ident{fv and resolve the similar ccmdationfor the other two reactor buthhng emergency coohngJims AH E lil and All-E lC. until Aptt! 24,1997 As a result.

reactor buildmg emergency coohng fans, AH E lB and AH-E lC. were onoperable contrary to 15 3.3. (03033) lhese violatwns m Section H1 represent a Seversty Level JH problem (Supplement 1). CivilPenalty. S$3.000.

GPUN RESPONSE TO VIOL ATIONS IN SECTION III .

' BACKGROUND As stated in the Section 11 response, the ECAPAT concluded that management did not apply sufficient

cmphasis and attention to QCL program oversight and corrective action activities; The ECAPAT observed numerous instances of weaknesses in the oversight ar.d correctne action areas His included failures to t

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6710 97 2483 Page 18 of 31  !

enter problems into the formal corrective action systems for resolution, inadequate investigations into the f estent and causes ofidentified problems, failure to follow through on agreed upon corrective actions, and tolerance of recurrence of deficiencies. ,

The ECAPAT concluded that within the GPU Nuclear organization there was not a proper level of recognition, respect and acceptance of the vital role of oversight and corrective action processes. The i ECAPAT inferred that management had not p%ced adequate importance on the timely identincation and resolution of process and program deficiencies,

'the ECAPAT believed that oversight and corrective action wcaknesses were prinarily the result of nanagement's failure to establish, communicate and enforce its expectations. Also, the ECAPAT believed  :

- that the GPU Nuclear emphasis on Teamwork and Leadership, although generally very positive and successful, might have been misunderstood relative to the relationship between line and oversight

organizations.

' i GPilN RESPONSE TO V101,ATION lil.A -

{ini Nuticar anrecs with the violation.

GPU Nuclear agrees that it uas a condition adverse to quality, in that items uhich could have had safety l signi6canec were not being resolved in a timelv manner.

Reason for the Violation The root cause was management tolerance of allowing longstanding technical issues to remain open .

When the Decay lleat Removal SSFI wm performed in 1992, procedural controls had not been established to ensure that conditions which could have safety significance be resolved in a timely manner. This may ,

have contributed to the problem oflack of attention to closure of the SSFI items.

Corrective Steps Taken and Results Achieved >

The DilRS pt..np vent valves have been added to the Environmental Qualification (EQ) Program.

Also, in the GPU Nuclear response to the NRC's 10CFR50.54(0 letter dated October 9,1996, GPU Nuclear committed to consolidate Systerr Design 11 asis Document and Safety System Functional Inspection  :

open items to achieve timely and effective resolution because these items has e remained open for years and .

additional management attention is being applied to closure; in htarch 1997 GPU Nuclear implemented the

- Corrective Action Process (CAP) s) stem, a computerized (Lotus Notes) database system which meets the requirements of the GPU Nuclear Operational Quahty Assurance Plan. The CAP system provides for a greater degree of management attention, root cause identification, determining the safety significance, and

tracking the closure of numerous issues like the issue cited in this violation The SSFl and SSDBD items

. has e now been entered into the CAP j e

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ATTACllMENT 1  !

6710 97 2483  :

Page 19 of 31  ;

Corrective Steos to be Taken to Avoid Further Violations i

Now that the CAP system is available for corrective action tracking. GPU Nuclear intends to use CAPS to track the remlution of future SSFI open items whenever other quahfied coractive action sy stems are not  ;

used.  :

Date when Full Compliante will be Achieved Full compliance has been achieved.

GPUN RESPONSE TO VIOLATION llLl!

GPU Nuclear anreen with the violahgIb Reason for the Violation The reason for the violation was a persistent organizational resistance to effective oversight. This was indicated by concerns in the following areas: a) escalation of quality deficiencies, b) conflict avoidance / resolution, c) misinterpretation of" performance-based QA". and d) misinterpretation of the principles of" Teamwork and Leadership." 6 L

Corrective Stens Taken and Results Achieved He specific items identified in this violation have been addressed by revision 5 of EP-Oll. As stated in the response to violation ll.A. the revised EP-01I has fonnalized the QCL process and includes written.

detailed standards related to component and program changes. EP 011 now requires a untten safety determinatiort' safety evaluation when the quality classification of a component is changed from a higher to lower classification Dese changes provide reasonable assurance that 10 CFR 50.59 requirements will be met when equipment downgrades are performed.

Additional actions are necessary to address the organizational resistance to efTective oversight. Actions that have been taken to address escalation of quality deficiencies are:

1) Senior GPU Nuclear management has issued guidance to clarify expectations on resohing and escalating quahty deficiencies.

2) A review of all outstanding QDRs has been completed to ensure that all have been properly escalated  ;

3) The Corrective Action Process (CAP) procedure has been revised to esplicitly incorporate escalation '

. into the CAP program and to establish expectations on the fomt content use, ownership, and oversight of corrective action systems.

Other actions in progress are discussed in the " Corrective Steps to be Taken" section below.

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• ATTACllMENT 1 6710 97 2483 Page 20 of 3l Corrective Steos to be Taken to Avoid Further Violations Several actions are bems taken to address conflict avoidanec/ resolution. Senior management will establish and communicate management's responsibilities and espectations for conflict resolution. Confhet resolution workshops will be held to emphasize management's responsibilities and espectations for conflict resolution. Monitoring will be implemented to determine the effectiveness of conflict avoidanec/ resolution corrective actiota

%e working definition of"perfonnance-based QA" will be clarified and communicated to the organimion to avoid any future misunderstandings

' Finally, team building workshops will be conducted with NSA and Engineering to clarify " Teamwork and Leadership" training in regards to the potential misinterpretation of these principles, Date when Full Compliance will be Achieved implementation of Revision 5 of EP-Oli addressed the specific items identified in this violation Completion of the corrective actions to address the broader issue of organizational resistance to effective oversight will be completed by 9/30/98.

GPUN RESPONSE TO VIOLATION ill C GPU Nuclear merces with the violation Henson for the Violation ne reason for the violation is personnel error. A review by GPU Nuclear found the contributing factors to the delay were: 1) belief by engineering personnel on site that the configuration for All E-1B and All-E.lc had been verified by walkdown following their last repair in 1986,2) belief by all engineering personnel involved that appropriate direction with supporting documentation had been provided for the original

. installation and 3) less than adequate communication between on site engineering and EQ cngineering personnel.

Corrective Secos That flate Been Taken And The Results Achieved GPU Nuclear completed the following actions to correct conditions that led to the violation:

• Procedures were reviewed to assure they contained appropriate prosision for timely reporting, documentation and resolution of operability concerns.

• Training was provided to Engineering groups on the procedural requirements and GPU Nuclear's espectations, regarding timeliness of operability determinations.

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• Communications between on site engineering and Corporate EQ Engineering has been impioved by (ne

' designation of an on site EQ cngineer This on site EQ cngineer works with Corporate EQ Engineering to ensure appropriate EQ resources are applied on site.

In addition td the above, the following actions were completed specifically to enhance the EQ Program:

• Planned 12R outage work on environmentally quali0cd companents was reviewed and an engineering walkdown of selected components was performed to assure that the con 0guration is consistent with environmental quali0 cation requirements.

• Engineering Procedure EP 0", " Equipment Emironmental Quali0 cation Program," was revised to enhance guidance for operability determination and supponing documentation for EQ components.

Corrective Stens That Will Be Taken To Asold Further Violations No additional corrective actions are planned.

j),gte When Full comoliance Will Be Achieved Full compliance has been achieved Secitan 11', 190LA 110NS ASSOCIA 71?D ll7711 EMi!RGl?NCl' PREPA RiiDNES.S 10 CFR 30.34(ql states, in part, that "a hcetuce authomed to possess and operate a nuclear pon er reactor shallfoHow and mamtain in e(fect emergemy plans u htch meet the standards in 10 CFR 30.47(b) and the requirements tn Appendix E qf this part. "

A. 10 CFR Part 30, Appendix E. Section D'B. " Assessment Acnons," requires. m part, that the means to be used,for determining the magnnude qf and pr connnuaHy assessing the Impact qf the release pfradwactn e matenals be described. Includmg the emergency action lewis that are to be usedfor determining when and uhat type qf

. protecttw measures shordd be c<mstdered unhtn and outside the site boundary to protect heahh and safety.

7hc GPil Nuclear Corporate Emergency Plan, which was Jewtoped m accordance with the ptvrtston of10 CFR Part 30, Appendix E and 10 CFR 30.47, Section 3,J.II.

" Direction and Coordmatwn." states, in part, that the Emergency Director as wsted with certain authonty ar d resp <n.:shthry that shall not be delegated to a subordmate.

mcludmg classafication qfemergency events.

The hcetisec's Emergency Plan implementmg Procedure (EPIP) IMI. 01, " Emergency Classifcation and Basis." item GL2 requires the declaration ofa general emergency pr the loss qf two of threefisswn product barriers wtth a p<nential loss pf the third barrier.

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Contrary to the above durmg the fullpcescapanon exerctse on Afarch 5.1997, the EPIP procedure 1All 01 nas not piloned on that the Emergency thrector faded to classtfv a general emergcmy uhen such a dcciaration uas warranted due to the simulatedloss of the threefis.uonproduct barriers. (040131 B 10 CFR 30 47(b)(10) requires. In part. that a range of protecnvc acnons have been developed for the plume exposure pathway emergemy planmng t'mc (EPZ) for emergemy workers and the pubhe, Guldchnes pr the choice of protective actions during an cmcrgemy, consistent uith Federal guidance, are developed and in place.

Secnon 20 of the GPU Nuclear Corporate Emergency Plan states. m part. that the Emergency plan is consistent wnh the guldchncs given In NUREG-0634 FEAM. REP-1.

"Craterta for Preparanon and Emluation of Radwlogical Emergency Resp <mse Plans and Preparedness on Support ofNuclear Pou er Plants " dated November.1980.

Secnon ll12 of NUREG-0634 states. In part. that for the worst possible accidents, protecnvc acnons u onld need to be taken outside the planning tones.

Contrary to the above. as of Afarch 5.1997, cmergency response trasmng uas not adequate and prmedures contamed insuffictent guidance for considermg protective actwn recommendations (PARS) bepmd the 10-mile EPZ As a resuh emergemy response management did not commun.cate recommendattons for PARS for residents Scymd the 10-mde EPZ uhen phome dose projectwns appeared to mdicate that protective actson guidehnes uvuld be exceeded beyond that tone durmg the fidi parncipatwn exercisc on Alarch !. 1997. (04023)

These violatwns m Sectwn 18' represent a Seversty 1.evel ill problem (Supplement I) Card Penahy S33,000 Gl'UN RESI'ONSE TO VIOL.ATIONS IN SECTION IV IMCKGRt 11No As stated in our responses to Confirmatory Action Letter (cal.) 1 97-011. our demonstrated perionnance did not meet our own expectations and prompt correctis e actions includmg a remedial exercise were warranted The root cause analysis of our hlarch 5.1907 exercise was performed by an expert multi organizational team. which addressed all the identified weaknesses The correctise actions identified by the root cause analysis team to address these siolations were completed prior to the hley 13-1097 remedial exercise. Additional corrective actions associated with improving the Emergency Preparedness Program are in progress.

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Page 23 of 31 i

I GPUN RESPONSE TO VIOLATION IV. A I

GPF Nuclear anrecs with the violation l l

Henson for the Violation The following factors have been identified as contnbuting to the failure by the Emergency Response Organization (ERO) to encognize and declarc the scenario designed General Emergency within the expected time frame: ,

1. Inteniews and w ritten drill materials (logs, tumont checklists, briefmg checklists) suggest that segments of the ERO had difdculty interpreting the appropriate Emergency Action Level (EAL) with respect to changing thermohydraulic conditions and fuel damage class.

2. Observer's and players indicated that the combination of the time in teleconference with the Emergency Support Director (ESD) and focus on reacting to the Decay llcat System rupture diluted the Emergency Director's (ED) ability to maintain big picture effectiveness This may have inhibited his timely evaluation of how changing plant conditions aligned with EALs for upgrading the event within the expected time frame of 15 minutes.

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3. The ERO missed an opportunity to declare the General Emergency on a recommendation from the ESD Assistant imraediately after the Decay llcat Removal system rupture. Inteniews indicated that the ESD and ED desired to further evaluate plant conditions such as RCS leakrate from Deca) Ilcat Removal system prior to declaration.

Corrective Stem Taken and Results Achieved initial training was given to the ERO on methods for detennining status of fission product barricts, with emphasis on which barricts are considered recoverable or unrecoverable. The initial and continuing training lesson plans were modified to include this information ,

The EDs and ESDs were given training on newly developed expectations and priorities with respect to impact on timely evaluations of plant conditions and comparison to EALs for identifying and declaring emergencies, The initial and continuing training lesson plans were modified to include this information.

Training was given to the Emerpncy Response Facility leaders to solicit, encourage, and consider input or recommendations from supporting stafTmembers. The initial and continuing ERO training lesson plans were resised to include this information. i The remedial exercise conducted on May 13,1997 provided confirmation that this deficiency was successfully corrected m

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o ATTACilhtENT l 6710 97 2483 Page 24 of 31 Date when Full Compliante will be Achieved Full compliance was achieved on hia) 13.1997 for this specific siolation Additional corrective actions associated with improving the Emergency Preparedness Program are in progress meluding a scheduled evaluation of the nest csercise to assess the efTectiveness of the corrective actions.

GPUN RESPONSE TO VIOL,ATION IV. H.

GPil Nurle).f_Riften with the violation Henson for the Violation The primary contributor associated with tin deficiency on the part of the emergency response organization (ERO) was inadequate requirements and espectations. A secondary contributor was inadeqcte scenano vahdation, which involved the radiological indications and esercise schedule EcWitementsEldnpeglati2n1 There was rat an espectation at the time of the hiarch 5,1997 csercise that there would be a need to provide recommendations outsiac of the 10 mile EPZ. A clarification of expectations has occurred as a result of the hiarch 5 exercise. The ERO is espected to ofter protective action recommendations beyond the 10-mile Ep2 when required This capabihty esisted within the organization but was not siewed as necessary. At the time of the hiarch 5 exercise, the emergency preparedness program included no routine dose projection models (Continuous On line Assessment and manual RAC code) which request input and provide output leadmg to dose projections, and subsequent recommendations, beyond the 10-mile EPZ The organization could hase, if tawed to do so, provided 10 to 50 mile FPZ dose projections and protective action recommendations using the hilDAS plume mateling program, though this feature was oot typically used by or addressed in training for ERO radiological positions.

Scenatioladthnicalmdicatiam During the esercise, the Group Leader, R&EC, and his support organization were in agreement with offsite o0icials that dose projections in excess of fifty rem CDE at the boundary of the 10 mile EPZ would warrant protective action recommendations (to be acted upon by the state) The Group Leader, R&EC, and his ERO stafT indicated that they felt an obligation to deselop recommendations beyond 10 miles, but lacked consistent radiological data to do so Specifically, while the manual RAC computer code indicated in escess of fifly rem CDE: the Continuous On line Assessment code indicated significantiv lower, and decreasing, doses; and field monitoring team data showed insigmficant offsite doses The root cause evaluation team has conci"ded that the reason the ERO did not respond promptly to the request for protective action recommendations for residents outside the 10-mile EPZ was the inconsistent radiological information provided to esercise participants by the scenario This problem was exacerbated by the offsite source term being significantly larger than the reasonably available source term.

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ATTACllMENT I 6710 97 2410 Page 25 of 31 brtfilmhedult As previously noted. the Group Leader, R&EC, and his staff fcit an obligation to provide protectise action accommendations to offute omcials for residents outside the 10-nule EPZ. The apparent need for such recommendations arose late in the esercise time line Due to radiological data inconsistencies, there wa., a need for appreciable consideration of actaal radiolagical conditions prior to offering recommendations. The Group Leader, R&EC, and his ERO staff were engaged in a process of deciding how to reconcile various, inconsistent radiological data in order to recommend protectise actions beyond the 10 rnile EPZ when the esercise was tenninated Corrective St*os that llave fleen Taken and Results Achieved Procedures used by the RAC and Group Leader, R&EC, hase been resised to incorporate the need to provide protective action recommendations to offsite officials for residents outside of the 10-mile EPZ when required A meeting has been held with the appropriate State omcials to discuss the process that would be used for providing PARS beyond 10 miles.

Procedures have been revised to direct a cross check of in plai.t survey data, onsi.e and offsite field team sune) data, Continuous On line Assessment code input, and espec:cd manual RAC code inputs dunng the development of drill and esercise scenarios The scenario validation process is used prior to the e<crcise to ensure scenario output is as espected.

Requirements and tools have been estabitsbed to evaluate perfonnance of dose assessment prior to using data for purrnses of PAR consideration Dose proicction code outputs have been modified to ensure dosv projections outside the 10 mile radius are readily available Date when Full Compliance will be Achieved Full compliance was achieved on May 13, IW7 for this specific siolatior.. Additional corrective acticas associated with improving the Emcrgency Preparedness Program are in progress including a scheduled evaluation of the nest esercise to assess the effectiveness of the corrective actions SlK'110Nl'. }'IGl.AllONS NOl' ASSliSSED A C!I7L PliNALIT A 10 CFR 30.49(f) requorcs cach ticm of electrocal equ:pment Important to safety to be environmentally quahtied by testmg or by comhmatwn of testmg and analystt to CFR 30 49(j) requires that a record of the environmental quahtication :

mamtalncd In an audtla'!" form to permll vertfication that cach tiem of clectric equipment Important to sorcty Is quahfiedfor Its opphcation and meets Its specttled performance requirements u hen It Is subjected to the condtilons predicted to be presem u hen It must perform Its safet) Jimction.

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ATTACINENT I  !

6710 97 2483 i Page 26 of 31  !

i Contrary to the above,from March 17. J986. untsiMarch 24. J997, the three reactor build.ng emergency coohngfcms ucre not environmentally qualfficd by testing and or [

analysts for post loss of coolant accident (LOCA) reactor butidmg atmospheric l condawns S >cc{ncally, the opphcatwn qf heat shnnk tubmg left a small length qf .

cKyosed conductor at the stMrk plug connector to cach qf thehn motors. ThcTc uas i no documentation to support the qual {Bcation of the motors wnh the cKposed {

conductors in thepost LOCA cnvironment in u hoch they uvuld be required tofuncnon As a result, the reactor butidmg emergency coohngfcms ucre Inoperable contrary to 15 3.3. (030/3) i This Is a Seversty lxvelill violation (Supplement il i

il 10 CFR Part 30. Appendix B. Cntenon l', states. In part, that activettes affecting quahty shall be accomphshed in accordance u'Ith Instnictions, procedures, or  ;

drautngs.

i Procedure SP 9000 44-001. " Instrument and Control Instrument Instalianon. "  ;

t Revision O. Section 3.3. spec (ncs the use qf protective barners uhcre separanon critetta cannot be met >

Procedure 1420-IIT 1, "lical Trace Repair and Replacement " Revleton 11 and the l vendor drau mg 13 30230. Reviston 2. provide Instruenonsfor the Installatwn qfheat tracing.

Contrary to the above, as pf December 2,1996, the as Installed connguranon of l llWST level transmttler DilLT-808 uas not in accordance unh the apphcable

• spectncanons. procedures, and drawtngs. Spectncally:

L 1hc protectnv barrierpr level transmuter Dil LT-808 was not mtact in that the cover plate u as open and thefastenersfor the cover u ere mtssmg.

2. The heat tracmg for level transmtuer DH LT-808 was not installed m accordance uith procedure 14,?0-HT.) and the vendor drauing in that the hea: ,

tracing was not wrapped annmd the sensmg hnes or the transmitter.

Wsthout the pny'er electrical separanon betueen redundant components or proper ,

heat tracing the level snmsmitter could haw been subject to a sangle finture or frecimg (06014) 1his as a Seventy Level n ' vwlation (Stqy>tement 1)

C. 10 CFR Part 30. Appendar B. Criterton XI. "Ik'st Control." requires, m part. that a test prognun shall be estabhshed to assure that all resung required to demonstnne that structures. systems, and components uill perform satiskictorily m servtce n i

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A*ITACllMENT 1 5710 97 2483 l' age 27 of 31 Identsficdandperformedtn asconomcc with urotten test procedurcs uhuh mcorporate the requirements andaucptaru e hmits contained m upphcable design documents

1. Contrary to the above as ofJanuary 10.1997. the test program failed to assure that the tests spectford by IEEE Report No. NSG TSC SC41. "Prolwed IEEE 1 Criteria for Class IE Electrical Systems pr Nuclear Power Generatmg Stations " June 196V, ucre identtficd nadperform,d !quectfically, molded case circutt brcalers In safety-rclared motoc control centers 1A ES ESF l'ENTand ih ESF ITNT had not been tested since they were mstalled m 1980 runtrary to IEEE Report No NSG 7ECSC41 uhuh spectfies that tests shall be performed at scheduled micreals to demonstrate that components that are not exerctsed durmg omrmal cperatmn are operable, i15AR Sectmi 81. " Design Baats."

states that tlte electrical system design satisfies IEEE Report No. NSG 75CSCJ.

1. (07014)

This is a Severity Levelll' vmlanon (Sepplement h

2. Contrary to the above, as ofDecember 2. I996, the test programfaded to anure that testing <tf safety related check wives required by 1S 4 2.2 In accordance unh 10 CFR 30.33a and Section XI of the American Soctcry of Alechamcal Enginecrs (ASAfE) and Pressure l'essel Code (the Code), uas identtlied and performed Spectfically, the DHRSpump chscharge check ndecs (DH.I'16A and

't) and the ball check wives located m thefloor drams of t're DHRS pump nudts ucre not tested m the chned position as specified by part 10 (oaf.lu) of AMIE ANSI UNa 1988 uhtch as referenced by Sectmn XI of the AMIE Code DHRS pump ducharge check wives have a safety.fsmetmn for prens.tmg back flow thus mamtaming low pressore miccl.on flow uhen one discharge header cross-connect .alves are open Ball che:L wives located m the floor drams of sne DHRS pump widts have a safety-relatedJimcrion m preventmgfloodmg of the other DHRS niult If neemve uater leakage occurs m one vauk (080)4)

This is a Scwrtty 1.evelIl' vmlation (Suppicment h.

.G. l'11N llESI'ONSE TO VIOL >ATIONS IN SECTION V GI'11N RESI'ONh1TO NOV V.A Gl't1 Nuticar nerecs with the viointion Brason for the violation The reason for the violation is inadequate engineering direction and dwumentation, which resulted in inadequate con 0putation control

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ATTACllMENT l  ;

6710 97 2483  :

Page 28 of 3i Corrective Steos That Have Been Taken And The Resular Arhieved l

1hc cable connection to the spark plug for All E l A fan motor was replaced with an environmentally quahned conhgumion on March 24,1997.

He cable connection to cach spark plug on both the All E lB and 1C fan motors was temporarily repaired v.ith an environmentally qualined conug'iration on April 24,1997. This temporary con 6guration was  !

' replaced with an environmentally qualified con 6guration during the 12R outage.  ;

Engineering change documentation was initiated to clearly delineate the EQ tequirements and provide an l as. built configuration of the cab lc to spark plug connection, and incorporated in the EQ Gle, Also, the .

Supplemental System Component Evaluation Worksheet (SSCEW) was revised to include a description of '.

I the acceptable configuration for the termination.

,- Corrware Steps That Will Be Taken To Avoid Further Violations The maintenance procedure associated with the fan cable connections will be enhanced to identify the req.litements for restoration of the connection during any futurc maintenance actisitics.

Date When Full Compliance Will Be Achieved 4 l'ull compliance was achieved on April 24,19o7. Approval of the revised maintenance procedure, which will be issued by April I,1998, will avoid further violauons.

GPitN RESPONSE TO NOV V.II.

GPU Nucley_atices with the violation.

Reason for the Violation

l. Level transnutter Dil LT 808 protective barrier was not intact in that the cos er plate was open and the fasteners for the cover were missing.

The reason for this was that this installation was in an out of the way location that was not easy to access and Surveillance Procedurc (Sp) 1302 5.19," Borated Water Storage Tank Level Indicator," did not specifically require that the enclosure cover be replaced at the conclusion of the surveillance.

2. The "as fcund" con 0guration was not in accordance .uth Nelson drawing ET-30250R2 and not in accordance with the TMI heat trace maintenance procedure 1420 IIT-1. This particular enclosure is provided for physical separation and not for thern.al insulation; a similar instalk tion, which has no enclosure, was found with heat trace prcper! installed *..>c apparent root cause was incorrect

' installation in 1988, possibly due to a lack of experience by the installers who also may not have been famihar with the requirements for this type of heat trace. Unlike an earlier heat trace design 1 which would has e piodded signincant heating (and the potential for over heatmg within an i

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. 4 ATTACllMENT I  ;

6710 97 2483  ;

Page 29 of 31  ;

enclosure), this self regulating heat trace is designed to mair.trin a specified temperature only for a  !

matenal in surface contact with the coils. GPU Nuclear believes that this is an isolated incident. l Carrective Steps Taken and Results Achieved I i

1. Level transmitter Dil LT.808 cover was reinstalled.  ;

i 2 Suntillance Procedure (SP) 1302 5.19,"Isorated Water Storage Tank Level Indicator," was revised in Revision 19 on February 5,1997 to ensure that the enclosure cover is closed after  :

I completion of the suncillance. <

3. The level transmitter Dil LT408, heat trace icitallation has been corrected.

i Corrective Stens to be Taken to Avoid Further Violatioru No additional corrective action is planned 3

i Mate when Full Comollance will be Achieved Full compliance has been achieved.

i GPUN RESPONSE TO NOV V.C.l GPU Nuclear arrecs with the violation.  ;

. Rttan for the Violation  :

The l A and til ESF Vent MCCs and associated molded ca se circuit breakers were not added to the PM '

Program when they were installed in 1986. This was caused by a weakness in the review process for modi 0 cations for maintenance impact (i.e., to determine required changes to maintenance programs, i schedules, and procedures). ,

improvements were made to the GMS 2 repetitive tasks in 1993, which resulted in specifk tasks to test these breakers. The schedule provided for the tests to be performed four years later based on the incorrect assumption that tests completed on the MCC feeder breaker tests had also tested these breakers.

Corrective Steps Taken and Results Achieved I. Tests of the three breakers (llW. Fil l. IlW.ll 001 and I1W.I1002) which are : . w: red from the

. I A & 1!! ESP Vent MCCs, which had not been completed by the close of the design inspection, have been completed  ;

A review was conducted of the molded case breaker PM tasks to ensure that all N3R MCC molded case breakers are included in the test program. Twenty breaker tasks were updated as a result of this review, which was completed on June 3,1997,

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4 ATTACithtEN T 1 l 6710-97 2483 Page 30 of 3I t

1 In 1988, tiic hiaintenance Assessment group was formed and the modi 0 cation review for numtenance testing was assigned as part of that group's responsibilities. This resulted in the process becoming more formalized. Specine individuals are now required to perform th;s review i function. as outhned in attachments to Administrative Procedures ( APs) 1021 and 1043 for t modification closcouts; omissions such as this are less likely to occur with the process in place  ?

toda).

Corrective Siens to be Tohtnto Avoid Further Violations I

No additional errecth e actions are planned. t I Date when Full Comoliance will be Achieved ,

Full compliance has been achieved  !

t GPt:N HF.SPONSIC TO NOY V.C.2. l t

4 GPtt Nuclear artes with the violation.

llowever, it is noteworthy that in respcnse to NRC inspection 96 201. GPU Nuclear has voluntarily  !

committed to it ciudmg the DilR Pump Vault ball check valves in the Augmented IST program. Smce these valves are no: ash 1E Class I,2, or 3 componentr., Technical Speci0 cations 4.2.2 requirements for '

4 sesting in accordance with 10 CFR 50.55a and the ASME Section XI Code do not apply.

Rfson for the )htion A Decay lic~.t Removal (DilR) Pump disenarge check vahes IDil Y 16A and B):

DibV 16A and D were not included in the ASME Section XI Inservice Test (IST) program because the determination of the safety ftmetions for these vahes was inadequate.

D. DilR P"mp Vault ball check valves:  ;

Although testing of the DilR Pump Vault check vah e Coor drains was included in a maintenance  ;

procedure (U 17) to addre<s the potential Goodmg of the ECCS pump rooms in rcSponse to IE .

CLeular 78 06, the ball check valves wete not included in that procalute.

E fact that tw difRrent types of Coor drain check valves (swing check valves and ball Goat check salves) are provided for the DilR Pump Vaults and the fact that the Ibor draia valve  !

con 0guration was not clear on the plant drawings (Hoor drains vahes were not individually .

identined on the plant piping and instrumentation diagranw P&lD) are believal to have contributed ,

to the omission of the DilR Pump Vault ball check valves from the inspection procedure.

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ATTACilMENT I i

6710 97 2483 Page 31 of 31 l Corrective Steos Taken and Resuks Achieved f A. DilR Pump discharge check valves (Dil V.16A and B):  !

1. Check valves Dil V.16A and B were tested in the closed position on December 19,1996 j and the results were satisfactory.

2. Closed function testing of the Dil V.16A and B check valves was added to the IST l program and the valves were tested for the closed function in accordance with ASME Section XI requirements during the 12R Outage m October 1997,

11. 1)llR Pump Vault ball check valves: ,

1. The DilR Pump Vault ball check valves were inspected and found to be Operable.

2. He DilR Pump Vault ball check valses have been added to the Augmented IST program l to assess their operational readiness.

- 3. The P&lD (Drawing No. 302 719) has been revised to include the DilR Pump Vault floor drain piping and valve arrangement ball check valve numbers were added to identify the valves individually.

Corrective Stens to be Taken to Avoid Further Violations During NRC Inspection 96-08 conducted between June 3 and September 27,1996, certain valves were identified that had not been incorporated into the ASME Section XI IST program as required. As corrective action for closure of the Quality Deficiency Report (QDR 962021) that was initiated because of -

+

that finding a thorough review of the IST program scope and implementation is being performed That review will be completed by April 30,1998.

Date when Full Comoliance will be Achieved l'ull compliance has been achieved f

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