ML20206E259
| ML20206E259 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/01/1987 |
| From: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 5211-87-2054, NUDOCS 8704130561 | |
| Download: ML20206E259 (5) | |
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GPU Nuclear NggIgf 100 interpace Parkway Parsippany, New Jersey 07054 201 263 6500 TELEX 136-482 Wnter's Direct Dial Number:
April 1, 1987 5211-87-2054 Dr. Thomas E. Murley Region I, Regional Administrator U.S. Nuclear Regulatory Comission 631 Park Avenue King of Prussia, PA 19406
Dear Dr. Murley:
Three Mile Island huclear Station, Unit 1 (TMI-1)
Operating License No. OPR-50 Docket No. 50-289 Response to SALP Report 86-99 l
Attached is our response to the TMI-l SALP which summarizes the information provided in our meeting of February 24, 1987. We have responded to the significant comments or issues in each functional area.
Overall we regard the SALP process as helpful. We recognize that by design it is largely devoted to identifying areas for improvement and our ongoing efforts are intended to address those areas. We are pleased that you recognize the results of our extensive efforts in the area of Plant Maintenance (including surveillance / testing). We believe that the outstanding plant performance is attributable to the emphasis we have placed in this highly critical area. We believe that one key to safety is preventing operator and equipment challenges through quality maintenance.
As discussed during the meeting, SALP reports are becoming more widely known and used.
Therefore, I believe it is particularly important that they be as consistent as practical among plants and that NRC emphasize prominently in each report the manner in which they can be appropriately utilized.
Sincerely, G704130561 070403 gDR ADOCK 05000289 P. R. Clark PDR President PRC/CWS/spb:2226g Attachment cc: TMI-l Resident Inspector's Office f
GPU Nuclear is a part of the General Pubhc Uhhties System
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l RESPONSE TO SALP REPORT 86-99 I.
Overview / Summary The report indicates in the sections on Plant Operations, Technical Support, and Assurance of Quality that improvements in procedure adherence, attention to detail, programs / policies and individual errors, would improve overall performance. All of these areas are being actively addressed.
Specific actions have been reported to connection with the Procedures Compliance Task Group (PCTG) you in and our recent responses to the NRC PAT inspections, previous SALP reports, and notices of violations.
The number and intensity of reviews by GPUN's internal review groups as well as INP0 and NRC generate a large number of somewhat overlapping findings and issues. We attempt to prioritize these issues and formulate actions which address all appropriate aspects to assure that our response is not fragmented and potentially ineffective. This coordination has resulted in some cases in delayed responses which we believe may have appeared to be weak, lack thoroughness in immediate actions, or lack responsiveness. Overall, during the past several years the number of open issues and the time required to resolve them has been decreasing.
II.
Plant Operations This section is critical of middle level management's i.ifluence regarding schedule pressure and shortsighted review u events. These insights are based on events cited as violations in Inspection Report 86-17 (IR 86-17). Management has been a positive influence in l
following procedures. We will continue to emphasize this at all levels l
of management.
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We do not believe that the plant incident report regarding HPI valve l
mispositioning was shortsighted. As explained in our response to IR 86-17, the operator properly selected the correct procedures.
Further, the procedures used were selected based on good judgment and not due to management pressure for productivity. The incident occurred i
due to individual failure to follow procedures regarding independent verification which was a requirement regardless of the choice of procedures. We have taken additional steps to strengthen our program for independent verification.
Regarding the adequacy of station procedures, we believe that improvements have been made as a result of our restart efforts and as a l
result of additional attention applied subsequent to NRC findings during l
the previous $ ALP. These improvements have resulted in procedures that are adequate and as a result are respected, trusted and used by the l
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. operators. Findings which occurred during this SALP period do not generally suggest significant procedural adequacy concerns. Rather, they suggest errors where people, design, operating conditions and/or maintenance do not come together correctly. We will continue to pursue improvement in our procedures and performance.
This section also attributes what the NRC characterizes as " repetitive poor responses" to lack of management involvement. We believe that Management has been involved and concurred in the responses to the NRC.
Our disagreement with the NRC should not be interpreted as lack of involvement and is not tentative. We propose a meeting with the NRC to discuss these disagreements and resolve the issue of "the need for and use of procedures." We share the goal of overall control of activities but believe it can and should be achieved through an appropriate combination of procedures, qualifications, experience, and training. We discussed this to some extent during our meeting of February 24, 1987.
We suggest that we discuss our observations related to the need for and use of procedures in a meeting during May 1987.
Safety review issues, are addressed in the section on Assurance of Quality.
III. Radiological Controls Semi Annual Effluent Report oversights have been corrected as described in response to IR 86-19.
IV.
Maintenance i
GPUN has no specific connents on this section.
V.
Surveillance Testing The comments concerning emergency feedwater check valve and battery testing have been resolved. The time required to resolve these items was necessary for a complete understanding of the issues.
Inservice testing is addressed in the Licensing section of this response.
VI.
Emergency Preparedness GPUN has no specific comments on this section.
VII. Security / Safeguards This section of the SALP report indicates that GPUN is "being too compliance oriented." The comment appears to be based almost entirely on not recognizing RER findings before the RER inspection. The RER Team's special forces members identified items which involved judgments on the degree of protection afforded.
Such judgments are always l
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. subjective and vary based on the perspective and the experience of the person. We accept their judgment and all significant items have been addressed.
GPUN has gone beyond minimum NRC requirements in many' areas.
With respect to material status reports,.we believe a change in L
guidance caused the identified item. The basis for our disagreement will be the subject of separate correspondence.
VIII. Technical-Support GPUN appreciates the NRC recognition that our modification control program is well established and that. training of engineering personnel has improved. Areas that are currently receiving special attention to provide further improvement include:
- Plant Engineering controlled efforts
- Drawing control
- Environmental Qualification
- Long range planning, including outage planning We believe our responses to the PAT inspection have resolved the. issue of support for analysis / design assumptions.
We believe that our handling of replacement-in-kind for replacement components is adequate.
It allows for reasonable interpretation.
While we have observed no examples of installations of inadequate equipment, Technical Functions will initiate a program of sampling reviews to assure that this area is being handled properly. This program will continue until we have assured ourselves that replacement-in-kind process continues to operate satisfactorily.
Specific Engineering review of startup test results is provided where acceptance criteria are not met or other specific concerns indicate a review is appropriate.
Drawing controls is going ahead in three areas. First;theassurance that all work packages contain the approved drawings. Second, improved maintenance of controlled drawing files. Third, improved use of the computer database system (CARIRS). Two key factors in the above are increased emphasis on training, especially in the areas of configuration control and the establishment of improved comunications.
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, Adequacy of EQ files has been, and will continue to be' an ongoing l
effort at GPUN. Our latest efforts in this area have been reported in conjunction with NRC Inspection 87-01.
t We believe the actions / reviews discussed above will serve to correct l
any inconsistent performance within this functional area.
IX.
Training and Qualification Effectiveness We are pleased that the NRC recognizes the extensive efforts we have l
applied in this functional area.
1 X.
Assurance of Quality This section of the SALP report largely discusses issues arising in other SALP functional areas, primarily our safety review process and the Corporate Procedure Task Group. We met with the NRC staff on February 12, 1987 and discussed these issues at length.
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i they are not discussed further herein.
l XI.
Licensing GPUN recognizes the need for timely licensing submittals, especially to support major outages. The start of the outage four months earlier l
than was originally planned due to exceptionally fine plant performance resulted in the submittal of some documents much later than desired.
To help prevent recurrence, NRC submittals have been added to the Long Range Plan to provide management attention and improved prioritization for work completion and timely submittal, j
With regard to Inservice Testing issues, NRC letter dated March 19, 1987 has closed the last of the IST-issues related to Cycle 6 startup.
These issues have remained open for an extended period largely because we believed at each stage we had reached a mutual understanding and resolved the issues only to discover in NRC October 3,1986 SER that was not the case. Further, the October 3, 1986 SER also contained new issues that had not previously been discussed. Our proposals have not been based on cost " strictly" but have been based on the belief that existing plant information and performance review was adequate to evaluate the performance of equipment in question. We continue to believe our positions were appropriate and technically adequate.
(See also Appendix B to our response to Inspection Report 86-17 dated March 5, 1987.)
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