ML20213G430
| ML20213G430 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| 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: |
| 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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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
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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. , Esquire
TMI-1 Hearing Service List
Chairman Zech
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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)
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W. D. Travers, Director, THI-2 Cleanup Project Directorate
J. Goldberg, OELD: HQ
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Management Assistant, DRMA (w/o encis)
DRP Section Chief
J. Stolz, NRR
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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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UNITED STATES
ENCLOSURE 1
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NUCLEAR RE'lULATORY COMMISSION
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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
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S. Collins, RI
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A. Blough, RI
W. Baunack, RI
F. Young, RI
R. Conte, RI
D. Johnson, RI
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J._ Rogers, RI
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Operations
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50-289
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TMI-1 H:aring Service List
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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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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
Projects (DRP)
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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
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3.
Commonwealth of Pennsylvania
A. Bhattacharyya, Nuclear Engineer
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ENCLOSURE 3
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GPU Nuclear
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Parsippany, New Jersey 07054
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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.
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Sincerely,
/"K. M
P. R. Clark
President
PRC/CWS/spb:2226g
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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
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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.
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.
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
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IR 86-17, the operator properly selected the correct procedures.'
Further, the procedures used were selected based on good judgment and
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not due to management pressure for productivity.
The incident occurred
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due to individual failure to follow procedures regarding independent
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verification which was a requirement regardless of the choice of
procedures. We have taken additional steps to strengthen ote program
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for independent verification.
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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
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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
combinationofprocedures, qualifications, experience'andtraininh87.We
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discussed this to some extent during our meeting 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.
"
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
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- Drawing control
- Environmental Qualification
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- 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
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components is adequate.
It allows for reasonable interpretation.
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While we have observed no examples of installations of inadequate
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equipment, Technical Functions will initiate a program of sampling
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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.
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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
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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.
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With regard to Inservice Testing issues, NRC letter dated March 19,
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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
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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
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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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