ML20211G417
| ML20211G417 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/24/1986 |
| From: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| Shared Package | |
| ML20211G422 | List: |
| References | |
| NUDOCS 8611030500 | |
| Download: ML20211G417 (3) | |
See also: IR 05000289/1985097
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24 OCT 1986
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Docket No. 50-289
GPU Nuclear Corporation
ATTN: Mr. H. D. Hukill
Vice President and Director of TMI-1
P. O. Box 480
Middletown, Pennsylvania 17057
Gentlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP)
Report No. 50-289/85-97
l
This letter refers to the SALP evaluation of Three Mile Island, Unit 1 for the
period of September 16, 1985 through April 30, 1986, initially forwarded to
you by our July 10, 1986 letter (Enclosure 1). This SALP evaluation was dis-
cussed with you and your staff at a meeting held on July 30, 1986 (see Enclo-
sure 2 for attendees). We have reviewed your August 19, 1986 written comments
(Enclosure 3) and herewith transmit the final report (Enclosure 4). Based on
a review of your comments, we made minor revisions to our report on . fire brigade
training (pages 11 and 29) and radiological controls audits (page 12). We have
also issued revised pages 19, 20, and Table 8 to correct editorial errors.
In your response to the SALP findings in the Plant Operations functional area
concerning fire protection training and drills, you indicated that you believe
NRC now agrees that your training and drills are thorough and realistic. A
more appropriate characterization of our position is that upon implementation
of the additional provisions discussed during the August 12, 1986, meeting, we
agree that your program will be more thorough and realistic.
Our overall assessment is that you and your staff have continued to demonstrate
competent management, and generally exercised effective control of activities.
Your cooperation in the SALP program is appreciated.
Sincerely,
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Thomas E. Murley
Regional Administrator
Enclosures:
1.
NRC Region I letter - T. E. Murley
to H. D. Hukill, July 10, 1986
2.
SALP Meeting Attendees
3.
GPUN letter, H. D. Hukill to
4.
SALP Report 50-289/85-97
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T. E. Murley, August 19, 1986
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0FFICIAL RECORD COPY
391BLOUGH10/14/86 - 0001.0.0
10/22/86
8611030500 861024
ADOCK 05000289
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24 OCT 1986
cc w/ encl:
R. J. Toole, Operations and Maintenance Director, TMI-1
C. W. Smyth, Manager, TMI-1 Licensing
R. J. McGoey, Manager, PWR Licensing
E. L. Blake, Jr. , Esquire
TMI-1 Hearing Service List
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
Chairman Zech
Commissioner Roberts
Commissioner Asselstine
Commissioner Bernthal
Commissioner Carr
bcc w/ encl:
Region I Docket Room (with concurrences)
W. D. Travers, Director, TMI-2 Cleanup Project Directorate
J. Goldberg, OELD: HQ
T. Murley
Division Directors, RI
Deputy Division Directors, RI
J. Durr
L. Bettenhausen
R. Bellamy
J. Joyner
K. Abraham (2 copies)
D. Holody
J. Taylor, IE
Management Assistant, DRMA (w/o encl)
DRP Section Chief
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Operations
50-289
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TMI-1 Hearing Service List
Sheldon J. Wolfe, Chairman
Bruce W. Churchill, Esquire
Administrative Judge
Shaw, Pittman, Potts & Trowbridge
Atomic Safety & Licensing Board Panel
1800 M Street, N.W.
U.S. Nuclear Regulatory Commission
Washington, D.C.
20036
Washington, D.C.
20555
Dr. Oscar H. Paris
Atomic Safety & Licensing Board
Administrative Judge
Panel
Atomic Safety & Licensing Board Panel
U.S. Nuclear Regulatory Commission
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555
Washington, D.C.
20555
Frederick J. Shon
Atomic Safety & Licensing Appeal
Administrative Judge
Board Panel
Atomic Safety & Licensing Board Panel
U.S. Nuclear Regulatory Commission
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555
Washington, D.C.
20555
Joanne Doroshow
Docketing & Service Section
The Christic Institute
Office of the Secretary
1324 North Capitol Street
U.S. Nuclear Regulatory Commission
Washington, D.C.
2002
Washington, D.C.
20555
Louise Bradford
1011 Green Street
Harrisburg, PA 17102
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Enclosure 1
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UNITED STATES
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REGION I
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KING OF PROSSIA, PENNSYLVANIA 19406
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10 JUL 1986
Docket No. 50-289
GPU Nuclear Corporation
ATTN:
Mr. H. D. Hukill
Director, TMI-1
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P. O. Box 480
Middletown, PA 17057
Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP); Report
No. 50-289/85-97
The NRC Region I SALP Board conducted a review on June 6,1986, and evaluated
the performance of activities associated with the Three Mile Island (Unit 1)
Nuclear Generating Station.
The results of this assessment are documented in
the enclosed SALP report, which covers the period September 16, 1985, to
April 30, 1986.
The Interim SALP which covered the period from September 16,
1985 to January 10, 1956 is also enclosed for completeness. We will contact
you shortly to schedule a meeting to discuss the report.
At the' meeting, you should be prepared to discuss our assessment and any plans
you may have to improve performance further. Any comments you may have regard-
ing our report may be discussed at the meeting. Additionally, you may provide
written comments within twenty days after the meeting.
Following our meeting and receipt of your response, the enclosed report, your
response, and summary of our findings and planned actions will be placed in the
NRC Public Document Room.
Your cooperation is appreciated.
Sincerely,
/
Thomas E. Murley
Regional Administrator
Enclosure:
As stated
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GPU Nuclear Corporation
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10 JUL 1986
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cc w/encls:
R. J. Teole, Operations and Maintenance Director, TMI-1
C. W. Smyth, Manager, TMI-I Licensing
R. J. McGoey, Manager, PWR Licensing
E. L. Blake, Jr.
TMI-1 OTSG Hearing Service List
Public Document Rcom (FDR)
local Public Document Roca (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
bec w/ encl:
Region I Docket Room (with concurrences)
DRP Section Chief
SALP Board Members
NRC Resident Inspector, CC
J. Taylor, IF
T. Murley, RI
J. Illan, F.I
PAO, RI
W. Kane, Ri
H. Kister, RI
F. Young, RI
R. Conte, R!
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Enclosure 2
TMI-1 SALP ATTENDEES
GPUN
P. Clark, President
R. F. Wilson, Director, Technical Functions
R. L. Long, Director, Nuclear Assurance
R. Heward, Director, Radiological and Environmental Controls
H. Hukill, Director, TMI-1
R. W. Keaton, Director, Engineering Projects
D. K. Croneberger,' Director, Engineering and Design
R. J. Toole, Operations and Maintenance Director, TMI-1
J. Thorpe, Director, Licensing and Regulatory Affairs
G. Kuehn, Manager, Radiological Controls, TMI-1
C. Smyth, TMI-1 Licensing Manager
NRC
T. Murley, Regional Administrator
R. Starostecki, Director, Division of Reactor Projects (DRP)
J. Stolz, Director, Project Directorate No. 6, NRR
S. Ebneter, Director, Division of Reactor Safety (DRS)
W. Kane, Deputy Director, Division of Reactor Projects
W. Johnston,- Deputy Director, DRS
H. Kister, Chief, Projects Branch No.1, Division of Reactor Projects
J. Durr, Chief, Engineering Branch, DRS
R. Blough, Chief, Reactor Projects Section IA, DRP
R. Conte, Senior Resident Inspector (TMI-1)
R. Weller, Section Leader, Projects Directorate No. 6, NRR
J. Thoma, TMI-1 Operating Reactors Project Manager, NRR
L. J. Callan, Chief, Performance Appraisal Section, IE
J. Dyer, IE
Commonwealth of Pennsylvania
A. Bhattacharyya, Nuclear Engineer
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inclosure 3
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GPU Nuclear Corporaticn
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Nuclear
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Middletown, Pennsylvania 17057-0191
717 944 7621
TELEX 84-2386
Writer's Direct Dial Number:
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August 19, 1986
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 (TMI-1)
Operating License No. DPR-50
Docket Nos. 50-289
Response to SALP Report 85-97
Enclosed is GPUN's response to the most recent SALP Report. The response is
formatted to reflect the major areas addressed in the NRC's Report. This
response and our response to the interim SALP (5211-86-2068 dated April 21,
1986) complete our response for this SALP period.
Sincerely,
.
. D.
kill
Vice President & Director, TMI-1
HDH/CWS/spb
Enclosure
cc:
J. Thoma
R. Conte
0631A
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ADOCK 05000289
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GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
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' Introduction
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As reflected inethe SALP repopt and our discussions on July 30, 1986,
sverall performance at TMI-1 has'been safe and competent and we have
well defined 7.nd solid programs'in place to continue to operate in a
safe and professional manner. 'We believe that the SALP report as
clart/ied in our discussion provides constructive input to our ongoing
effort, and NRC. comments during the July 30 SALP meeting, basically
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agree with our evaluation.
Our goal is to continue to' improve our performance by ensuring that
management's goals and our programs are fully understood and
implemented at all levels within our organization. Major efforts will
be directed towards this end. +These efforts will also be directed
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specifically at instilling in our people, especially middle management
and first line supervisors, the requirement for " attention to detail"
in their activities.
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With startup and initial operati[n successfully behind us, we expect to
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see an increasing level of understanding and experience in our staff.
We believe our personnel.bre improving in the area of attention to
detail and that experience' wi. tis close management attention and guidance
will be major contributors to '6ilt improvement.
As confirmed in the SALP we.have a good procedure system. We agree
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that additional efforts are feeded to upgrade procedures and to be more
consistent and demanding of our, people in the area of procedural
compliance. The actions discu6srd in our response to the Interim SALP
(attached) continue. We will also re-einphasize to our supervisors that
they are responsible for; procedure implementation on a continuing basis
and must, therefore, proparly review procedures and closely oversee
implementation practicer.
Continued efforts are underway to improve preventive maintenance as one
factor in reducing unplanned reactor trips and challenges to safety
systems., .<In addition, we are actively engaged with the B&W Owners
Group in reviewing and developing programs to reduce trips and
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challenges to safety systems.
' We agree that improvement in impleme$ ting our programs in the area of
modification and maintenar.co support'if needed. Our answer to the PAT
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Safety System FunctionabInspection ouscribed many of our initiatives
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in this area which are underway and receiving direct management
overview and assessment.
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The SALP report makes1 the observation that/gsome activities are
. performed in a hurried manner to" meet schedules and that this sometimes
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results in problems.
In our judgement, the' pace of activities has, for
the most part, been appropriate: Our evaluation of the unplanned
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exposures and radiological releases as discussed in our letter dated
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July 15,1986 (5211-86-2122) indicate that they resulted not from the
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high pace of activities, but rather from a mistake in judgement and
lack of experience in opening the Reactor Coolant System shortly af ter
the plant had been shut down. We do understand that meeting schedules
can cause problems if not properly managed and planned. We will
continue to monitor this factor to ensure our middle managers
understand and comply with the appropriate pace of activities and don't
attempt to meet schedules by failing to comply with procedures.
There are some comments in the sat.P report which are characterized as
involving improper management attitude. We have reviewed these and as
discussed in our meeting do not believe there are such attitudes. We
believe that the observed situations result from lack of understanding
between us, differences in judgement on priority or lack of attention
to detail.
We very strongly endorse the Chairman's and the Executive Director's
initiative to establish performance objectives. This program if
properly developed would help provide clear and measurable standards to
supplement the subjective evaluations inherent in the current SALP
process. We would be more than willing to participate in the
development of such a program.
II.
Plant Operations
Procedures - addressed in Introduction.
Attention to detail - addressed in Introduction.
Pace of activities - addressed in Introduction.
Major efforts are underway to improve logkeeping and ensure that out of
specification readings are identified and reported to the Shif t
Supervisor / Foreman so that appropriate action can be ,taken, if
warra nted.
Specifically, the following actions have been implemented:
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The Manager of Operations has issued memos reinforcing logkeeping
practices.
2.
QA Monitors have been requested to specifically observe logkeeping
practices.
3.
Those conducting management tours have been requested to observe
logkeeping practices.
During our meeting on August 12, 1986, we described the extent of our
fire protection training and drill program. Based on these discussions
and clarifications, we understand that you now agree that our training
and drills are thorough and realistic and provide meaningful training.
As we discussed, the drill that was the subject of the alleged
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violation in Inspection Report 86-01 was not typical of fire drills at
TMI-1 and no credit was given for that drill.
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III.
Radiological Controls
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A detailed review of the circumstances surrounding the airborne
radioactive buildup in the Reactor Building following shutdown 'and
personnel entry to the building has been conducted. The lessons
learned from this event have been documented and promulgated to
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appropriate personnel. Our evaluation and report of corrective action
for this event is contained in our response to Notice of Violation from
Inspection Report 86-05-(GPUN letter 5211-86-2122 of July 15, 1986).
We agree that in most instances direct irwolvement of upper / middle
level plant management in detailed work should be limited and directed
to training and assuring supervision. This matter has been discussed
in detail with those involved. Senior management is closely' monitoring
the situation and providing individual direction where ~needed.
This section refers to QA audits of the radiation protection program.
As discussed in our meeting, the audits referred to were conducted by
Rad Con nott by,QA. These audits are required by the Radiation
Protection Plan and were initiated by the Rad Con management in order
to improve 'the quality of their activities. Overall audit plans are
now used in order to assure that all program elements are reviewed.
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IV.
Maintenance
We agree that major jobs are well planned, superviced and carried out
but that more routine and minor work is not always perforced in as
complete a manner. This is an indication of operating experience level
and attention to detail.
Increased mariagement and supervisory
attention will be applied in order to improve performance of
maintenance and engineering support thereto for all maintenance
activities, not just major jobs'.
Based on our discussions at the July 30, 1986 SALP meeting, we
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understand that the level of documentation has, in some cases, created
an appearance of insufficient inquiry / evaluation of problems. We agree
that our documentation can be improved to capture more completely the
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basis for our corrective actions and to make this more visible to the
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NRC. We will increase our efforts in this area. We believe, however,
that the depth of our reviews and evaluations have generally been
adequate, notwithstanding our documentation.
In response to a concern previously expressed by the NRC, Plant
Engineering conducted a review of job tickets to identify instances
where minor modifications have been accomplished incorrectly as job
tickets without proper engineering documentation.
Engineering reviews
. and QA monitorings requested by management identified approximately 20
instances where modifications had been accomplished as job tickets.
Nearly all of these have been evaluated to date and either removed,
accepted as is, or upgraded.
Maintenance management has been
instructed to be watchful for instances where this may occur in the
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future so that it can be prevented and/or corrected.
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V.
Suneillance Testing
The issue concerning the use and understanding of the Exception and
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Deficiency forms we believe has been resolved.
Recent changes to
procedures have clarified the forms use. We intend to continue to
monitor this area to verify that this problem has been corrected.
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With respect to the procedures used to test our battery capacity:
(1) GPUN has been both aware of and understands the current industry
standards for battery testing and (2) we did consider adopting the most
current test methods at the time the "A" Battery replacement
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Operability / Maintainability /Constructability Review (OMCR) was
conducted. We are continuing our evaluation of the new standards and
will adopt them if it is determined they are technically superior to
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our gurrent battery operability test methods,
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VI.
Startup Testing
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No comments.
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VII.
As discussed in our meeting, we believe, the noise and congestion in
the Control Room is largely caused by the artificiality of the drill in
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that drill controllers and obseners are present. Their presence
causes a degree of noise and congestion that would not be present under
non-drill conditions. We will take action to minimize this disturbance
during future drills.
SALP Recommendation
(1) Assess the effectiveness of dose assessment and in-plant health
physics functions in emergencies dealing with longer term
scenarios where the EOF and OSC are fully operational.
Response:
We believe that the dose assessment function during
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emergencies is being conducted logically and effectively.
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Further, based on our discussions on July 30,1986, we
believe it is being conducted in the manner that the NRC
desires as discussed below.
During emergencies, all dose assessment is initially
conducted by the RAC in the control room. This dose
assessment includes both in-plant and off-site dose
assessment / projections. The in-plant dose information is
needed and used by the Emergency Director (ED) during all
phases of an event in order to make operational decisions.
The off-site dose projections are also needed by the ED to
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make protective action recommendations prior to the
Emergency Support Director (ESD) arrival.
Once the ESD
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position is manned, protective action recommendations are
made by the ESD. The ESD uses off-site dose projections
performed by the Environmental Assessment Command Center
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(EACC) which is manned at the alert level.
Depending on
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drill timing, complete transfer of off-site dose assessment
from the RAC to the EACC may not occur immediately. This
function may be performed by both the RAC and EACC for a
short period of time until the transfer is complete. Our
drills to date have all included a full transfer of
responsibility for off-site dose assessment from the RAC to
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the EACC.
Once this is done, the RAC continues to perform
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in-plant dose assessment for the ED to support plant
operational decisions and provides source term information
in support of the EACC.
Off-site dose assessment is done
by the EACC at the EOF providing direct support for the ESD.
VIII. Security and Safeguards
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In a recent letter to the NRC, GPUN committed to resolving the
perimeter intrusion detection system issue by December,1987.
Although initial corrective actions did not correct the badge control
problem, as indicated by the report, subsequent actions were taken and
have been effective in correcting the security badge control problem.
IX.
Technical Support
We understand this section covers primarily modifications and design
and does not address many aspects of technical support such as
training, emergency procedures, startup testing, plant transient
review, risk analysis, etc. Many of these activities have been
commented on favorably in other sections of the SALP report and some
are not directly addressed in the report.
GPUN has long recognized the need for in-depth technical support to the
operating plants. The Corporation has made a major commitment over the
last five years as demonstrated by the resources applied. This
includes technical involvement in working with, and overseeing the
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results of almost every facet of plant operations.
This SALP technical support assessment is essentially based on the NRC
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Performance Appraisal Team report of modification / design problems in
one of two plant systems reviewed as documented in Inspection
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50-289/86-03. Our detailed response to the Performance Appraisal Team
Inspection Report was contained in our letter of June 27, 1986
(reference letter 5211-86-2099).
Regarding plant modification / design
support, we note that the SALP report recognizes GPUN has an
established program which contains appropriate controls for
modification activities.
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We recognize the need to improve the detailed implementation of the
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modification / design program.
We are putting a significant effort into
staff (including contractors) training, procedural clarification and
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working with first line supervision to ensure improvements in program
implementation. We have also reviewed our QA audit program. Our
review supports the continued shift towards greater emphasis on
identifying technical issues which includes assessment of engineering.
The PAT confirmed that this shif t, which commenced prior to the PAT
review, is appropriate and should be retained and reinforced. A
continuing refinement of this program is ongoing to ensure a balanced
review of technical and programmatic parfornance is achieved. One or
two of these balanced performance appraisal type audits will be
conducted in the next 18 months.
SALP Recommendations
(1) "In light of recurring problems in the environmental qualification
(EQ) area, assess the adequacy of or the need for better
accountability on specific engineering projects, such as EQ."
Response:
The environmental qualification area is one in which very
substantial problems were identified in the spring of 1984,
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in part through NRC inspections and assessment. We have
made sweeping changes in program, pecple, resources,
responsibilities and effort. We have re-reviewed changes
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made and conclude they were appropriate and the
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improvements required both by the NRC and ourselves have
largely been obtained. The issues identified in the
Performance Appraisal Team assessment largely deal with the
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adequacy of in-plant confirmation.
We have reverified all
of the common EQ items in the plant.
Our recent efforts
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have not detected any issues which arise from uncertainty
in accountability.
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(2) " Conduct a critical evaluation of the design review process with
emphasis on the role of peer review adequacy and first line
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supervisory oversight."
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Response:
As outlined in our response to the Performance Appraisal
Team, the design review process and its implementation is
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currently being critically evaluated. This internal
assessment has confirmed the need for improved attention to
details particularly in the area of design verification and
overall documentation. We have started actions to improve
the performance in these areas principally through staff
training, procedural clarification and greater supervisor
involvement. As mentioned earlier, we had begun and are
going to further reinforce our QA audit program to provide
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ourselves more consistent insight into our attention to
detail through in-depth, technical and program assessments.
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X.
Training and Qualification Effectiveness
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Training on procedures in the modification control area is discussed
above under Technical Support.
Procedure adherence has been and will continue to be emphasized by
management. Further, as indicated in our response to the Interim SALP,
a Corporate Task Force has been formed at the request of the Office of
the President to review all divisions' implementation of policies and
attitudes for procedural compliance. The report of the Task Force is
in final preparation.
Its recommendations and findings will be
evaluated and appropriate actions taken to strengthen procedural
compliance.
XI.
Assurance of Quality
SALP Recommendations
(1) Establish and enforce a policy that can be understood by mid-level
managers and workers to ensure procedural adherence and resolve
the perception that schedules are of a higher prioHty.
(2) Reassess the process used for assuring individual procedures are
technically adequate and complete.
In particular, assess the
relative roles of peer review and management oversight in
procedure reviews and changes.
Response:
We agree that more attention is needed by management and
supervision in ensuring that procedures are adequate and
maintained up-to-date.
Increased management awareness and attention to Quality
Assurance Department (QAD) effectiveness reviews will be
given especially in the area as noted in our reply to the
Interim SALP.
Increased QAD monitoring of procedural
adequacy and compliance was conducted at the specific
request of the Director, TMI-1.
The results were reported
to him, as well as to other cognizant managers and
supervisors. This increased monitoring and surveillance
uncovered several minor procedural issues that had
heretofore gone undetected.
Also, as discussed in our reply to the Interim SALP, a
Corporate Task Force has been established to review
procedure compliance and change programs and their
implementation in all divisions. This Task Force has
completed their review and is preparing the final report
for senior management. We believe this detailed report
will clearly demonstrate the strengths, weaknesses and,
just as important, variations in procedural policy between
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divisions in the Company.
It is management's intent to
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incorporate the strong points highlighted in the report;
while also developing actions to improve ~ weak areas in all
divisions.
It is also our intent to establish a standard,
practical company-wide policy for procedural adherence that
can be understood by all employees and can be enforced
consistently by managers and supervisors.
With regard to the " pace of activities," see Section I
" Introduction" above.
(3) Assess the need for better indoctrination and/or training for
individuals associated with engineering design work and design
change control.
Response:
Our response to the PAT inspection (5211-86-2099, June 27,
1986) described procedure enhancements related to
engineering and design work. These enhancements are
designed to correct the weaknesses identified in the PAT
inspection which are at the root of the SALP assessment.
These enhancements combined with appropriate
training / indoctrination on them as well as other training
described in our PAT response are responsive to this SALP
finding.
XII.
Licensing
GPUN is pleased that the NRC has recognized the improvements made in
Licensing. . This has been an area of concerted effort and will continue
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to receive much attention.
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GPU Nuclear Corporation
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Post Office Box 480
Route 441 South
Middletown Pennsylvania 17057-0?9
717 944 7621
TELEX 84 2386
Writer's Direct Dial Number:
April 21, 19P6
52)1-86-2068
Or. 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 (TMI-1)
Operating License No. DPR-50
Docket No. 50-289
GPUN Response to the TMI-1 Restart SALP Report
This letter provides GPUN's comments on the March 17, 1986 SALP Report as
clarified by our meeting with you on March 31, 1986. We are pleased that the
report and your comments during the reeting conclude that the TMI-1 restart
was safe and well controlled.
Our responses to previous inspection reports (IR 85-22, 25, 27 and 30) address
the root causes of specific items identified in the SALP Report.
Those
responses are not repeated here.
There were however three general issues
identified in the report.
These issues relate to Use and Quality of
Procedures,
Use of Oversight Group Findings,
and Technical
Support.
A
discussion of these items is attached which includes appropriate actions taken
or planned to improve our performance.
We believe the SALP process is an overall useful process in that it provides
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additional diverse insight into the quality of our activities.
Sincerely,
~
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H. D. Hukill
Director, TMI-1
HDH/CWS/spb
Attachment
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GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
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Use and Quality of Procedures
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TMI-l uses over 2500 procedures, most of which were revised and uograded
during the 6-1/2 year shutdown.
Specifically, we believe our AT00,
procedures were a major improveme nt.
GPUN did anticipate that some
minor procedure problems would surface during the restart as more and
more of the procedures were used under normal operational conditions.
Indeed some problems were noted both by the HRC and by GPUM.
The
problems identified were generally minor and caused no safety problems.
While we have made major improvernents in our procedures, we believe
additional improvement can be achieved. To this end, and as a result of
the procedural problems identified, r,Pillt has completed or will complete
the following items:
1.
the TMI-l Director has discussed procedural compliance and the need
to
identify
required
changes
with
all
Plant Operations
and
Maintenance personnel,
2.
procedure compliance and
identifying needed changes have been
discussed at the TMI-l fianagers tieeting,
3.
procedural guidance has been issued to clarify which circumstances
require written procedures,
4.
various nemos have been issued to document the above items,
5.
at the request of the THI-l Di rector, OA specifically monitored
procedural compliance and reported its results, (This monitoring is
conti nui ng. )
6.
a large number of PCRs have been processed to correct problems
identified during the startup that had not been turned in during the
startup (these had been saved up by ~ individuals we believe to avoid
disrupting the restart program with minor items),
7.
the discussions for items 1 and 2 above have included work habits
such as housekeeping and usi ng sensitive equipment in lieu of
ladders or scaffolding,
8.
the t1anagers conducting off-shif t tours and the OA shif t monitors
have been requested to emphasize procedural compliance and work
habits,
9.
finally, a Corporate Task Force has been established to review the
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safety related procedures and their implementation in all divisions.
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II.
Use of Oversight Group Findings
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The SALP Report at page 12 identifies three items.
Each item is
discussed below:
A.
Disposition of NSCC Recommendations
The SALP Report indicated that " Board dispositions for some NSCC
recommendations were not clear".
The following is provided to
clarify handling of NSCC recommendations.
NSCC is composed of three
outside members of the GPUN Board of Directors.
NSCC members as
such
attend
the
monthly
Board meetings
and report on
their
activities.
In accordance with its charter, the NSCC provides to
the
Board
a
semi-annual
report.
This
report
includes
any
.
recommendations.
The
report's
recommendations
are
formally
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responded to by the Prasident GPUN.
The NSCC evaluates those
i
responses and in subsequent reports provides the results of these
assessments.
At the direction of the GPUN Board these NSCC reports
are provided formally to the NRC.
B.
Management
Response
to
Assessments
Regarding
Procedure
Implementation Problems
i
As discussed at the SALP Meeting, QA assessment reports indicated
minor procedural implementation problems.
We consider our procedure
system to be sound and effective if properly inacted.
Management
did respond to QA assessments and emphasized procedural compliance
and the need to ensure procedures are up-to-date;
however, it is
apparent that stronger and more forceful actions were needed to
prevent
recurrence
of
these
problems.
Significant management
attention has been focused in this area as indicated in Iten I.
above.
C.
IOSRG Recommendations
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This item arises from a memorandum written by an IOSRG staff member
to his Manager on September
5,
1984.
It was occasioned by a
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corporate-wide assessment of verification procedures performed by
NSAD/IOSRG at the request of the Office of the President.
The memo
represented the personal opinion of this IOSRG staff merrber.
After
some consultation and reflection the 10SRG Manager rejected the
recommendations contained in the memorandum.
The recommendation was
not distributed by the IOSRG for further action and it remained a
piece of internal IOSRG correspondence.
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III. Technical Support
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The Restart effort placed a heavy burden on the Plant Engineering
staff.
This, with the need to explain engineering technical decisions
to various company and NRC oversight groups, stretched this technical
support to its limits.
Decisions had to be made concerning the priority
of each issue and the depth of documentation appropriate to be developed
in the near term. We believe that the on-site engineering and technical
support is a
uate, however
we consider that greater use of the
available off-s te technical , support is also necessary.
GPUN will
re-emphasize the need to more fully utilize Technical , Functions off-site
resources.
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