ML20214W711
| ML20214W711 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/03/1987 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.6, TASK-TM 5211-87-2111, NUDOCS 8706160149 | |
| Download: ML20214W711 (4) | |
Text
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GPU Nuclear Corporation
- Nuclear
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Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:
June 3, 1987 5211-87-2111 Mr. William T. Russell Region I, Regional Administrator US Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Russell:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Response to Inspection Report (IR) 86-17 Independent Verification Our letter of April 29, 1986 was in response to IR 85-27 regarding GPUN's commitments toward NUREG 0737, Item I.C.6.
IR 86-17 commented on our April 29,1986 letter and again requested additional information on the implementation of GPUN's commitments on independent verification. This letter is in response to IR 86-17.
NRC accepted the implementation of GPUN commitments to NUREG 0737, Item I.C.6 in IR 82-16 dated October 5,1982. Another inspector followup item regarding the implementation and documentation of independent verification was closed out by IR 83-02 dated March 10, 1983 where it was concluded that independent verification was acceptable.
It appears that the NRC now wishes to expand the scope of GPUN commitments to apply the independent verification program to the full scope of nuclear safety related equipment without following the NRC's specific procedures for backfitting.
IR 86-17 requested additional information and expressed concerns which this letter will address. However, this letter does not represent additional commitments toward NUREG 0737, Item I.C.6.
Subsequent to our letter of April 29, 1986, GPUN has completed preparation of a list of the critical components that require independent verification.
AP 1067, " Independent Verification Program" was issued in December,1986.
This procedure provides clarification of the circumstances where independent verification is applicable and includes the list of critical components.
AP 1067, Revision 1 was issued in March,1987 to incorporate the changes as a result of modifications performed during Cycle 6 refueling.
8706160149 070603 PDR ADOCK 05000289 G
PDR GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
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5211-87-2111 June 3, 1987 The TMI-1 Independent Verification Program was intentionally limited to those systems / components for which the risk and consequences of their misposition could result in a significant potential for offsite dose.
This is consistent with NRC Information Notice 84-51 concerning independent verification.
Because of the large number of systems and components involved in the plant, it is essential that the independent verification program be limited to those components where misposition could result in serious safety consequences.
If the program is too broad, it becomes less manageable and more error prone.
IR 86-17 states that GPUN's program was somewhat consistent with the TMI-1 restart hearing commitments, but related restart hearing correspondence and documentation was confusing in terms of the scope of equipment that would have independent verification measures applied.
The TMI-1 commitment to NUREG 0737, Item I.C.6 was reviewed and approved by the NRC prior to restart following the plant shutdown after the accident at TMI-2. We feel that our commitments as well as the scope of the independent verification program are clear, especially now that the procedures specify verification at the component level. We are not aware of any inconsistencies.
IR 86-17 states that the scope of expansion of the program described in our letter of April 29, 1986 "... centered around the containment integrity checklist and EFW alignment since this system was not yet fully safety grade." Our letter did include an expansion of the existing independent verification program to include the containment integrity checklist and ITS/NSR electrical jumper, lifted leads and safety function bypasses to the completion of a procedure and/or maintenance. The EFW System however, safety grade or not, was always part of the independent verification program.
IR 86-17 states that the elements (2) and (4) of I.C.6 dealing with the authority to release equipment and notification of control room operators were not addressed, and that our letter of April 29, 1986 was not completely responsive to the NRC staff's concern.
Element (2) is satisfied by the existing program in that we designate the Shift Supervisor as the individual responsible for release of equipment for maintenance and surveillance activities (AP 1029, AP 1001J, and AP 1002).
Element (4) is satisfied by the existing program in that the control room operators are informed of changes in equipment status and the effects of such changes (AP 1002 and AP 1001J). The inspector's " residual concerns" as expressed in IR 86-17 are addressed as follows:
- 1) Maintenance and Surveillance Testing.
Equipment control measures that should be addressed are component tagging; temporary modifications, startup from outage valve lineups; and restoration to normal from maintenance and/or surveillance testing.
Response: This item has been addressed in the approved AP 1067.
- 2) Authority to Release Equipment. The licensee should provide a description (or by reference) of these release authority provisions.
Response: The approved AP 1067 describes the provisions for release of equipment and discusses the other interacting administrative procedures (AP 1002, AP 1013, and AP 1001J).
y 5211-87-2111 June 3, 1987
- 3) Second Qualified Person and Significant Radiation Exposure. TMI TAP I.C.6 (3) recommends that except in cases of significant radiation exposure, a second qualified person should verify correct implementation of equipment control measures.
Response: This item is addressed by the approved AP 1067 and AP 1002 by reference.
- 4) Changes in Equipment Status. TMI TAP I.C.6 (4) provides guidance that control room operators be informed on equipment status changes and effects of such changes. Although apparently discussed in Administrative Procedures, this is not addressed in the licensee program description.
(It does appear to be adequately covered by various Administrative Procedures, but the licensee should review their APs to confinn this.)
Response: We have reviewed our administrative program at TMI-l and have confirmed that we have complied with our previous commitments. The approved AP 1067 compliments this program commitment.
5)
Independent Verification.
This NRC concern is over the adequacy of the scope of the independent verification program.
Response: The scope of the independent verification program at THI-l is defined to include those systems / components for which their misposition could cause a potential offsite dose approaching 10CFR100 ifmits.
This scope is consistent with NRC Information Notice 84-51 " Independent Yerification". The inspector indicated that our letter of April 29, 1986 provided " insufficient justification" to eliminate some systems from our program; however, it should be noted that our letter did not attempt to provide justification for not including that which was not included in the program nor was it our intent to reiterate FSAR design assumptions for each system.
Neither of the two examples given in IR 86-17 (control over the reactor building missile shield door and the restoration from a normal gas tank release) represent situations where a mispositioning could credibly cause a 10CFR100 release. We do not feel that either of these examples meet NRC criteria for Independent Yerification.
Procedures which currently define or implement the independent verification program at THI-l are as follows:
AP 1029
- Conduct of Operations AP 1013
- Bypass of Safety Function and Jumper Control AP 1067
- Independent Verification Program OP 1101 Containment Integrity and Access Limits AP 1002
- Rules for the Protection of Employees Working on Electrical and Mechanical Apparatus OP 1102 Plant Startup OP 1102-1
- Plant Heatup to 525'F AP 1001J
- Tech. Spec. Surveillance Testing Program
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5211-87-2111 June 3, 1987 These procedures are available at the site for NRC review.
Changes to improve these procedures or others in the future which may relate to the independent verification program will preserve GPUN's previously approved commitments to NUREG 0737, Item I.C.6.
However, GPUN is not increasing the scope of commitments beyond that which has already been approved.
If the NRC wishes to increase its requirements, a substantial improvement in overall safety would need to be demonstrated through the backfit process to support the additional requirements. GPUN has reviewed the current scope of the independent verification program and we do not believe that additional requirements would benefit safety. We believe that minimizing human error is a universal goal, not uniquely enhanced by a universal pro!1 ram of double
-performance. Independent verification, as a program, shou' d be applied to those activities with the highest risk and most costly consequences of human error. Over-application of this program would dilute the effectiveness of the program and detract from the attention to detail required of the individual operator.
i Sincerely, (l&
H.kHukill Vice President & Director, TMI-1 i
HDH/MRK/spb:0889A cc:
R. Conte, USNRC
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