ML20205K152
| ML20205K152 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/19/1986 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.6, TASK-TM 5211-86-2027, NUDOCS 8602270159 | |
| Download: ML20205K152 (5) | |
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Post Off;ce Box 480 Route 441 South Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number February 19, 1986 5211-86-20/7 Dr. Thomas E. Murley Region I, Regional Administrator U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pa.
19406
Dear Dr. Murley:
Three Mile Island Nuclear Station Unit 1 (THI-1)
Operating License No. DPR-50 Docket No. 50-289 Notice of Violation Response for Inspection Report 85-27 Attachment A to this letter is GPUN's response to Violation C of Appendix A to Inspection Report No. 50-289/85-27 " Notice of Violation." This response is being submitted late as discussed with NRC resident inspectors R. Conte and F. Young.
Sincerely, H. D. Hu ill Director, TMI-l HDH/MRK/spb:0491A Attachment cc:
W. Kane R. Conte Sworn and subscribed to before me this /f W day of 6 4fvA cv
, 1986.
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e Attachment A FINDING:
C.
Technical Specifications 6.5.1.1 and 6.8.2 require, in part, that changes to safety-related administrative control procedures be reviewed for adequacy.
Contrary to the above, between September 5,1984 and November 27, 1985, changes (revisions) were made to several safety-related administrative control procedures (AP) dealing with independent verification of safety-related activities, and these changes were not completely reviewed for adequacy in that:
Several APs required independent verification for a scope of equipment less than safety-related as reflected in the staf f's safety evaluation report (NUREG 0680, Original Supplement, page C2-5) or as required by TMI - Task Action Plan Item I.C 6 (NUREG 0737).
(These APs were AP 1001 A, Revision 9, June 3,1985, " Procedure Review and Approval;"
AP 100ld, Revision 3, January 3,1985, " Technical Specification Surveillance Testing Program;" AP 1002, Revision 36, October 14, 1985,
" Rules for the Prctection of Enployees Working on Electrical and Mechanical Apparatus;" and AP 1029, Pevision 70, November 12,145,
" Conduct of Operation."
Administrative procedure 1003, Revision 17, dated October 23, 1485,
" Bypass of Safety Function and Jumper Control," requires independent verification for important to safety systems without upttiting this requirement into subtier operating, surveillance, and maintenance procedures dealing with important to safety systems such as the liquid waste disposal system.
This is a Severity Level IV Violation (Supplement I).
RESPONSE
GPUN agrees in part with this violation in that review and approval of AP 1013, Revision 17, conducted pursuant to T.S. 6.5.1.1 and 6.8.2, resulted in inconsistencies with some of the subtier procedures.
However, we differ in regard to certain basic aspects of the violation and some of the supporting statements presented in others sections of the Inspection Peport (IR 85-27).
To a certain extent, the violation appears to be based on the assumption that HUREG 0737 Task Action Plan (TAP) Item I.C.6 imposes a stricter requirement for independent verification than was originally intended and that CPUH made commitments toward a broader scope of independent verification than was actually mdde. We believe that thIs Violation reflects a new Interpretation of NRC requirements and/or GPUH commitments.
9 Clarification of NUREG 0585, Recommendation 5, " Verification of Correct Performance of Operating Activities" was provided in HUREGs 0660 and 0737, Item I.C.6 " Guidance on Procedures for Verifying Correct Performance of Operating Activities." Licensees were required to review and revise procedures as necessary to ensure an effective system of verifying the correct performance of operating activities. An acceptable program for verification of operating activities was described, however in this context other specific programs might also be acceptable.
GPUN's response to NUREG 0737 included a response to Item I.C.6 as references to specific commitments in our Restart Report which addressed the requirement of NRC's Order dated August 9,1979.
Our commitment to independent verification included only the ESAS and EFW systems.
These commitments were expressed not only in our correspondence but also in testimony during the heari ngs. The staff's safety evaluation report (NUREG 0680, Original Supplement, page C6-4) also references our commitment accurately.
NRC's acceptance of these commitments was documented following its post implementation review.
NRC closed out TAP !.C.6 in Inspection Report 82-16 dated October 5,1982 and opened a new item regarding the implementation and documentation of independent verification. That open item was closed out concluding that independent verification was acceptable.
Therefore we believe that this violation represents a new interpretation of a previously accepted staff position.
It appears that the reference to page C2-5 of the Restart Report SER (NUREG 0680) is inappropriate and taken out of context.
The question responded to on that page clearly addresses EFW valves and safety related valve positions to ensure proper operation of engineered safety features.
In response to a statement on page 46 of the Inspection Report, we are not aware of any occasion where GPUN representatives committed to or led the NRC staff to believe that independent verification of component positioning (valves and switches) subsequent to maintenance and testing would be accomplished for a broader scope of safety related components.
The Inspection Report (page 2, Inspection Results) provides NRC concurrence that THI-l Restart Hearing commitments have been met.
Inspection Reports 82-16 and 83-02 confirm NRC acceptance of the adequacy of THI-l compliance with NUREG 0737, Item I.C.6 on independent verification.
GPUN's program for independent verification has not decreased in scope subsequent to NRC approval. Therefore, we do not believe that operation in accordance with our current commitnents to independent verification constitutes a violation of NRC requirements.
At the NRC's request, we have committed to reevaluate our commitments toward TMI Task Action Plan (TAP) Item I.C.6 and to provide a restatement of the independent verification program and our commitments to NRC by April 1,1986 as discussed with the NRC senior resident inspector on February 19, 1986.
e
/ GPUN desires to comment on other details presented in IR 85-27 where our understanding dif fers somewhat from NRC's findings. These are as follows:
a.
The Inspection Report stated that between September 5,1984 and November 27, 1985, changes (revisions) were made to several safety-related administrative control procedures dealing with independent verification of safety-related activities.
It was implied that this included Revision 9 to AP 1001 A, Revision 3 to AP 100ld, Revision 36 to AP 1002, and Revision 20 to AP 1029.
Changes made in these revisions however had nothing to do with independent verification. The only revision to an AP that dealt with this subject was AP 1013, which was revised to broaden the scope of verification required rather than to reduce the scope. If it is implied in Inspection Report 85-27 that changes to TMI-l procedures have reduced the scope of independent verification during the period of time referred to, it should be pointed out that no such changes have been made to reduce the scope of independent verification.
b.
Section 7.4 of the Inspection Peport states that a step in one of the procedures calling for verification of redundant component operability when taking equipment out of service included not only ESAS and EFW, but alsa RPS and PfiS.
The Inspection Report inplies that this represents an inconsistent definition of ESAS.
Our conmitments on independent verification provided in our letter of November 8,1979 specifically addressed RPS and Pf15 in addition to ESAS and EFW but only to the extent of supervisor verification of the documentation.
We do not believe that inclusion of additional systems into this commitment or any procedural requirement clouds the definition of ESAS.
Nor do we f eel that there should be any confusion in regard to those systems or components which receive an ES actuation sigm1 simply through variations in use of the ESAS acronym.
Engineered Safeguards is defined in Chapter 6.0 of the FSAR.
The terms
" Emergency Safeguards Actuation System" or " Safety Features Actuation System (SFAS)" have been used occasionally in place of the proper expression, " Engineered Safeguards Actuation System (ESAS)." We do not feel that any of these terms should be confusing to anyone who is knowledgeable about Tti!-1 systems, c.
Inspection Report 85-27 states that Revision 17 to AP 1013 was responsive to a recommendation from 10SRG (but not timely or ef fective).
- However, the referenced memorandum, prepared by a member of 10SRG, was addressed only to his manager. We are not aware of this recommndation ever h1ving been issued as a reconnendation by the 10SRG.
It is our understanding that the changes to AP 1013 in Revision 17 my have been prompted independent of the 10SPG.
Subsequent to the referenced remorandum, in response to the NPC IE Information Notice 85-51 which dealt with Independent Verification,10SPG concurred with the current TMI-l independent verification program and referenced NRC acceptance of the program and its implementation.
Therefore, these changos should not he viewed as corrective action in response to an 10SRG recommendation since such a recommendation was not issued.
- The procedural change which resulted in inconsistencies in our independent verification program was Revision 17 to AP 1013, not AP 1003 as referenced in the Inspection Report.
Revision 17 to AP 1013 " Bypass of Safety Functions and Jumper Control" broadened the administrative controls over lif ted leads and jumpers from independent verification of Nuclear Safety Related (NSR) systems to a scope which includes Important To Safety (ITS) systems. The inconsistency arose when this change was reviewed and approved without providing for the update of the lower tier procedures which were af fected.
This oversight caused inconsistencies between AP 1013 and some of the subtier operating, surveillance, and maintenance procedures which still need to be revised to reflect this new scope.
Out of the large number of procedures that could have steps that might be affected, only a few inconsistencies have been identified.
It will require a complete cycle or tne detailed periodic procedure review process to ensure that any other inconsistencies are identi fied.
I.
Corrective Steps Which Have Been Taken and Results Achieved Procedural changes to provide consistency of subtier procedures with AP 1013 are in progress.
II. Corrective Steps Which Will Be Taken To Avoid Further Violations We intend to provide a clear philosophy of the circumstances requiring independent verification and provide any needed improvements in what has been for the most part a very effective program.
Supervisors will review the independent verification program with all operations and mintenance personnel.
Procedural changes to eliminate those inconsistencies between AP 1013 and the lower tier procedures, which have been identified, will be implemented by May,1986 Procedure owners will be advised to look for any additional inconsistencies and make any necessary changes during the periodic procedure review process.
In order to avoid further violations of this, type in the future, GPUN will emphasize to the members of the plant review group the need to thoroughly review all procedure changes for their potential impact on other procedures.
III. Date When Full Compliance Will Be Achieved Although we have committed to reevaluate GPUN commitents on independent verification, we do not feel that the company is in violation of our l
commitents or HUREG 0737, Item I.C.6 requiremnts.
l With the exception of the review of all procedures, the actions described in section !! to achieve compliance will be conpleted by Hay,1986 l
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