ML20205T671
| ML20205T671 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/02/1987 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 0784A, 5211-87-2031, 784A, NUDOCS 8704070359 | |
| Download: ML20205T671 (4) | |
Text
s GPU Nuclear Corporation
,d Nuclear
- ,orrs r8o a
a Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84-2386 Writer's Direct Dial Number:
April 2, 1987 5211-87-2031 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C.
20555
Dear Sir:
Three Mile Island Nuclear Station Unit 1 (TMI-1)
Operati g License No. DPR-50 Docket No. 50-289 Respc e to PAT II Inspection xeport 50-289/86-14 This letter is written in response to your November 6,1986 Performance Appraisal Team (PAT) Inspection Report (50-289/86-14).
The report identified weaknesses in six (6) areas. These areas being Operator Reviews, Drawing Control, Post Modification Testing of Remote Shutdown Panels, Deficient Procedures, Responsible Technical Reviewer Knowledge, and Safety Review Icocess.
A meeting was held with Region I on February 12, 1987 in which the subjects of the Safety Peview Process and Responsible Technical Reviewer Knowledge were discussed.
Since this meeting was held, this letter will not address this issue.
GrUN performed an integrated test of the Remote Shutdown Panels on March 22, 1987. This test was witnessed by the TMI-l NRC Resident Inspectors.
The following is a summary of actions accomplished or planned in the remaining three areas.
Operator Reviews The valve lineup errors and procedure revision discrepancy were reviewed and determined to be isolated cases of administrative type errors. Plant procedures were followed and the proper reviews conducted, however some administrative inconsistencies existed with those reviews and procedural implementation. Corrective action has resolved each of these specific errors and a followup memo has been sent to all Shift Supervisors to ensure these errors are not repeated.
8704070359 870402
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PDR ADOCK 05000289
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G PDR GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation D
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5211-87-2031 April 2, 1967 The GPUN identified calculation problems were reviewed by the Operations staff and found to be a procedural error that caused an inappropriate algebraic manipulation. This procedural error was immediately corrected by changing the procedure to correct the algebraic formula. Additionally, the Control Room staff was briefed on the procedural error to ensure a more thorough understanding of the overall calculation. Although an error had been made during the original procedure development, the strong overall review process -
conducted by GPUN detected this relatively minor problem and took appropriate corrective action so that no safety problem existed at any time.
The followup memo mentioned above his been expanded to include the concern over this calculation error. Identifying these-type of errors to the operating crews has been determined to be effective in minimizing these types of problems.
Drawing Control The EFW System has been upgraded in stages over several outages and therefore it has provided unique configuation control issues.
The drawing was intentionally not revised to show that the block valves were not electrically connected because that part of the job was not released for plant operations.
The block valves as a system boundary 'were turned over to the plant but the block valves were not to be operated, and would not be, until the rest of.the EFW System upgrade was completed.
The valves were locked in a position not to interfere with the safe operation of the EFW System. The interim condition was identified in the tie-in document signed by Plant Operations and administratively controlled by the operator via Operations Procedure 1106-6.
Complete turnover of this system will happen at the end of the current 6R Outage, and the flow diagram 302-082 will then be revised to show the final configuration of the EFW system. This is not a configuration control issue and no further action is required.
The removal of the check valve EF-V3 internals was not noted on the drawing because a Field Change Notice (FCN) was not issued. A Field Change Notice is the document that causes the drawing to be revised after a change-is made ~ to the plant.
In this particular instance, the internals of the valve were removed and an FCN was written but not released. The completed FCN was not formally issued because of lack of timely approval by the responsible engineer within the Plant Engineering Department. The FCN has now been processed, and a revision of the drawing has been issued. Plant Engineering Management has -
emphasized to their engineers the importance of timely processing FCNs.
The backlog in the production and distribution of Micro Aperture Cards (MAC) was attributable to the transfer of this responsibility from the original plant AE (GAI) to the Engineering Data and Configuration Control (ED&CC) j section of GPUN. Certain problems in the software that was used to control this function were identified soon after the transition.
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5211-87-2031 April 2, 1987 corrective action was defined and implemented, a large backlog of MACS had accumulated. Additional resources have been applied to eliminate the backlog, while also processing all new drawing releases. GPUN now considers the MAC distribution to be in a normal flow of approximately three weeks. _During this j
perit d, CARIRS will reflect the existence of the drawing revision.
i The CARIRS system has been reviewed and several steps have been taken to make the input to CARIRS more timely.
The steps taken should ensure a minimum of i.
time delay from issuance of a document until it is entered in CARIRS.
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Deficient Procedures The issue of Technical Functions procedures'being classified ITS/ NITS was discussed in the previously mentioned February 12, 1987 meeting.
Misclassification of Special Temporary Procedures (STPs) has been reviewed.
l Specific guidance on classifying STPs has been included in the TMI " Procedure Review and Approval" procedure.
On plant engineering modificat#ans to classify " testing conducted after the modification was not required to-be reviewed by the Plant Engineering personnel who developed the modification" as a weakness in the program is not appropriate. Most of the modifications engineered by Plant Engineers are minor in nature. A good portion of the post modification testing is covered by appropriate surveillance procedures which have specific acceptance criteria. Test results for Surveillance and Maintenance Procedures get reviewed / approved by qualified personnel in the Operations / Maintenance Departments. These same individuals are qualified to review similar data following most Plant Engineer produced modifications. To require a formal e
engineering review of test results that meet all acceptance criteria is j
unnecessary and not an efficient use of engineering time. Plant Engineers i
will become involved with the review and disposition of any test results which do not meet specific acceptance criteria.
I i
For the modifications performed by Plant Engineers where unique /special post modification testing requirements are necessary, we will take steps _to ensure that the modification documents contain sufficient criteria to judge acceptability.
If we consider Post Modification Testing review necessary by i
engineering, we will note this on the modification documentation and Plant Engineers will review / approve the test results.
l Instruction has been sent to Plant Review Group (PRG) members on the classification and technical problems identified by PAT II. Specific guidance was included for the EQ portion of safety reviews.
In addition, further training is being conducted for preparers of safety evaluations.
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5211-87-2031 April 2, 1987 Conclusion In summary, GPUN has reviewed the specific problems identified in the PAT II Report including a review of the broad picture where applicable. Although this letter only addresses the six areas of "significant findings," the detailed findings were also reviewed and are being addressed.
Sincerely, Ng y
,1 ki
. D.
Vice President & Director, TMI-l HDH/MRK/spb:0784A cc:
T. Murley, USNRC R. Conte, USNRC J. Taylor, USHRC
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