ML20213G430

Forwards SALP Rept 50-289/86-99 on May-Oct 1986,including Minor Revs to Table 8,per Util .Util Commended for Strong Orientation Toward Nuclear Safety

ML20213G430
Person / Time
Site:	Three Mile Island
Issue date:	05/06/1987
From:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Hukill H GENERAL PUBLIC UTILITIES CORP.
Shared Package
ML20213G433	List: IR 05000289/1986099 ML20213G430
References
NUDOCS 8705180284
Download: ML20213G430 (3)

See also: IR 05000289/1986099

Text

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MAY 0 61987

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.

50-289/86-99

This refers to the SALP evaluation for Three Mile Island, Unit 1 for the period

of May 1, 1986 through October 31, 1986 initially forwarded to you by our

January 5,1987 letter (Enclosure 1). This SALP evaluation was discussed with

you and your staff at a meeting held on February 24, 1987 (see Enclosure 2 for

attendees). We have reviewed your April 1,1987 written comments (Enclosure 3)

relative to the report and find that as a result of your letter, no changes to

the body of the report are necessary. However, based on your comments at the

meeting and as a result of our followup, we have made minor revisions. to

Table 8.

In your response to the SALP findings, you propose a meeting in May 1987 to

further discuss GPUN management's involvement in violation responses and your

observations related to the need for and use of procedures. My staff will

contact you to establish an agenda and date for this meeting.

Our overall assessment is that you and your staff continue to exhibit a strong

orientation toward nuclear safety, that your organization is comprised of-

highly qualified and well trained personnel, and that many of your initiatives

go beyond regulatory requirements.

Your cooperation in the SALP program is appreciated.

Sincerely,

Original Signed By

WILLIA 11 T. RUSSEIL

William T. Russell

Regional Administrator

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OFFICIAL RECORD COPY TMI-1 SALP 86-99 LTR - 0001.0.0

04/24/87 -

_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _

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o- -GPU Nuclear Corporation 2

MAY 0 61987

Enclosures:

1. NRC Region I Letter, T. E. Murley to H. D. Hukill dated January 5,1987

2. SALP Meeting Attendees

3. GPUN Letter, P. R. Clark to T. E. Murley dated April 1,1987 ,

4. SALP Report No. 50-289/86-99

)

cc w/encls:

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

Chairman Zech l

Commissioner Roberts  !

Commissioner Asselstine

Commissioner Bernthal

Commissioner Carr

Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

Commonwealth of Pennsylvania

bec w/encls:

Region I Docket Room (with concurrences)

! W. D. Travers, Director, THI-2 Cleanup Project Directorate

, J. Goldberg, OELD: HQ

l' Management Assistant, DRMA (w/o encis)

DRP Section Chief

J. Stolz, NRR

l

'

G. Edison, PM, NRR

K. Abraham, PA0 (2 copies)

R. J. Bores, DRS3

SALP Management Meeting Attendees

NRC Resident Inspector, OC

.J. Taylor, DEDRO

C. Haughney, NRR

P. Polk, NRR

W. Russell, RI

J. Allan, RI

D. Holody, RI

W. Johnston, RI

T. Martin, RI

W. Kane, RI

S. Collins, RI

A. Blough, RI

W. Baunack, RI

F. Young, RI, TMI-1

R. Conte, SRI, TMI-1

D. Johnson, RI, TMI-1

0FFICIAL RECORD COPY TMI-1 SALP 86-99 LTR - 0002.0.0

04/23/87

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0FFICIAL RECORD COPY TMI-1 SALP 86-99 LTR - 0003.0.0

04/23/87

. UNITED STATES ENCLOSURE 1

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KING OF PRUSSIA. PENNSYLVANIA 19406

JAN 5 E6i

Docket No. 50-289

GPU Nuclear Corporation

ATTN: Mr. H. D. Hukill

Director, TMI-1

P. O. Box 480

Middletown, PA 17057

Gentlemen:

Subject: Systematic Assessment of Licensee Performance (SALP); Report

No. 50-289/86-99

The NRC Region I SALP Board conducted a review on December 3, 1986, and evalu-

ated 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 May 1, 1986, to October

31, 1986. 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 regarding our report may be discussed at the meeting. Additionally,

you may provide written comments within twenty days after the meeting.

Follcwing 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,

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Thomas E. Murley

Regional Administrator

Enclosure:

As stated

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cc w/encls:

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.

TMI-1 OTSG Hearing Service List

Public Document Room (PDR)

Local Public Document Room (LPDR)

-

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

Commonwealth of Pennsylvania

bec w/ encl:

LRegion I Docket Room (with concurrences)

DRP Section Chief

SALP Board Members

NRC Resident Inspector, OC

J. Taylor, IE

P. McKee, IE

T. Murley, RI

J. Allan,-RI

PAO,'RI

W. Kane, RI '

S. Collins, RI

', A. Blough, RI

W. Baunack, RI

F. Young, RI

R. Conte, RI

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D. Johnson, RI

J._ Rogers, RI

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Operations 18

. . . 50-289

,

TMI-1 H:aring Service List

.. ,

Sheldon J. Wolfe, Chairman Bruce W. Churchill, Esquire

Administrative Judge Shaw, Pittman, Potts & Trowbridge

Atomic Safety & Licensing Board Panel 2300 N Street, N.W.

U.S. Nuclear Regulatory Commission Washington, D.C. 20037

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, Esquire Docketing & Service Section

Three Mile Island Alert, Inc. Office of the Secretary

315 Peffer Street U.S. Nuclear Regulatory Commission

Harrrisburg, PA 17102 Washington, D.C. 20555

Louise Bradford Mary E. Wagner, Esquire

1011 Green Street Office of Executive Legal Director

Harrisburg, PA 17102 U.S. Nuclear Regulatory Commission

Washington, DC 20555

Thomas Y. Au

Assistant Counsel Commonwealth

of Pennsylvania

Dept. of Environmental Resources

Bureau of Environmental Resources

Room 505, Executive House

P. O. Box 2357

Harrisburg, PA 17120

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7

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ENCLOSURE 2

List of Attendees

SALP Management Meeting - February 24, 1987

1. GPUN. ,

G. Baker,' Manager, Environmental Controls, TMI-1

P. Clark, President

J. Colitz, Plant Engineering Director, TMI-1

R. Heward, Director, Radiological and Environmental Controls

H. Hukill, Director, .TMI-1

J. Knubel, Nuclear Security Director

G. Kuehn, Manager, Radiological Controls, TMI-1

R. Long, Director, Nuclear Assurance

R. McGoey, Manager, THI-1 Licensing

M. Roche, Deputy Director, Maintenance Construction and Facilities

C. Smyth, TMI-1 Licensing Manager

J. Thorpe, Director, Licensing and Regulatory Affairs

R. Toole, Operations and Maintenance Diractor

G. Troffer, Director (Act), Maintenance Construction and Facilities, TMI-1

2. NRC

.

R. Blough, Chief, Reactor Projects Section 1A, Division of Reactor

t

Projects (DRP)

R. Capra, Acting Branch Chief, Reactor Projects Branch No.1, DRP

R. Conte, Senior Resident Inspector, TMI-1

W. Kane, Director, Division of Reactor Projects

T. Murley, Regional Administrator

T. Ross, TMI-1 Project Manager, NRR

J.,Stolz, Director, PWR Project Directorate #6, NRR

R. Weller, Section Leader, Project Directorate #6, NRR ,

3. Commonwealth of Pennsylvania

A. Bhattacharyya, Nuclear Engineer

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+ ENCLOSURE 3

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GPU Nuclear

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M l { 100 Interpace Parkway

Parsippany, New Jersey 07054

201 263-6500

TELEX 136-482

Writer'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 19400

Dear Dr. Murley:

Three Mile Island Nuclear Station, Unit 1 (TMI-1)

Operating License No. DPR-50

Docket No. 50-289

Response to SALP Report 86-99

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,

/"K. M

P. R. Clark

President

PRC/CWS/spb:2226g

%ttachment

cc: TMI-1 Resident Inspector's Office

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GPU Nuclear is a part of the General Public Utilities System

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RESPONSE TO SALP REPORT 86-99

l

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) and our you in

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. P1 ant Operations

This section is critical of middle level management's influence

regarding schedule pressure and shortsighted review of 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

following procedures. We will continue to emphasize this at all. levels

of management.

n We do not believe that the plant incident report regarding HPI valve

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mispositioning was shortsighted. As explained in our response to

IR 86-17, the operator properly selected the correct procedures.'

i

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Further, the procedures used were selected based on good judgment and

not due to management pressure for productivity. The incident occurred

l due to individual failure to follow procedures regarding independent

l

verification which was a requirement regardless of the choice of

,

procedures. We have taken additional steps to strengthen ote program

l 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

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result of additional attention applied subsequent to NRC findings during

the previous SALP. These improvements have resulted in procedures that

are adequate and as a result are respected, trusted and used by the

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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

Man'agement 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

We

combinationofprocedures,

discussed this to some extent qualifications,

during our meeting experience'andtraininh87.

of February 24, l

.

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

GPUN has no specific comments 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

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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

guidance caused the identified item. The basis for our disagreement

will be the subject of separate correspondence.

VIII. Techni::al 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

p components is adequate. It allows for reasonable interpretation. ,

While we have observed no examples of installations of inadequate

i

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.

~

i 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, the assurance

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

i 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

effort at GPUN. Our latest efforts in this area have been reported in

conjunction with NRC Inspection 87-01.

We believe the actions / reviews discussed above will serve to correct-

any inconsistent performance within this functional area.

IX. . Training and Qualification Effectiveness

We are pleased that the NRC recognizes the extensive efforts we have

applied in this functional area.

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. Therefore,

they are not discussed further herein.

XI. Licensing

GPUN recognizes the need for timely licensing submittals, especially to

support major outages. The start of the outage four months earlier

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.

i

.

With regard to Inservice Testing issues, NRC letter dated March 19,

l 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

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'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

I- 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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