ML20236K366

Forwards Rept Which Provides Results of Audit Conducted by NRR of Commitment Mgt Program at Plant

ML20236K366
Person / Time
Site:	Three Mile Island
Issue date:	07/02/1998
From:	Thomas C NRC (Affiliation Not Assigned)
To:	Langenbach J GENERAL PUBLIC UTILITIES CORP.
References
NUDOCS 9807090288
Download: ML20236K366 (12)

Text

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July 2, 1998 p

L Mr. James W. Langenbach, Vice President L and Director - TMI-1 i: GPU Nuclear, Inc.

P.O. Box 480 Middletown, PA 17057

SUBJECT:

NRR AUDIT OF LICENSEE PROGRAMS FOR MANAGING COMMITMENTS MADE TO THE NRC i .;

Dear Mr. Langenbach:

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~The enclosed report provides the results of an audit conducted by the Office of Nuclear Reactor I Regulation of the commitment management program at the Three Mile Island Nuclear Station, Unit No.1. The insights gained from the audit at your facility will be used, along with the results from similar audits of seven'other licensees' commitment management programs, to determine

_ what, if any, changes to NRC policy or regulations are warranted. in addition, the staff has 1 i , undertaken discussions with the Nuclear Energy Institute to determine if changes in their  ;

guidance document, " Guideline for Managing NRC Commitments," might be mutually beneficial I for licensees and the NRC staff. The staff's efforts and recommendations in this area will be presented in reports to the Commission later this year.

We thank your licensing staff and other wrsonnel who participated in the audit for their L

cooperation. ' If you have any questions or comments conceming this report or the related

' efforts to improve NRC and industry guidance in the area of commitment management, please

- contact Timothy G. Colburn at (301) 415-1402 or William Reckley at (301) 415-1314.

Sincarely, /

/

. Original signed by Robert A. Capra l

L for Cecil O. Thomas, Director Project Directorate 1-3 f)

Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket No. 50-289 ,

DIST BUTION C j]2{fj (( ((l[] h}[

Enclosure:

Audit Report PDl-3 R/F TColburn JZwolinski WReckley ccwlencl: See next page ACRS CHehl, RI

, Docket Filei DOCUMENT NAME: G:\COLBURN\lic_rpt ltr- ~

To receive _a copy of this document, indicate..in the box: "C" - Copy without attachment /enclosuret n"E"-Cop 9withattachment/ enclosure "N" = No copy 0FFICE Po!*3/PM Vafj l P0l*3/LAJ sp()- lE P0lli 3 l PDI 3/D NAME TColburn 8-TClark V(7\( ./ WReckley LQ W CThomas Ro t fo r DATE 06/ A /96 - 06/ c2b /96 06/ B.") /98 07/ R -/90

, , - 0FFICIAL RECORD COPY

, 9807090288 980702 PDR ADOCK 05000289 P PM

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I J.Langenbach Three Mile Island Nuclear Station, Unit No.1 cc:

1 Michael Ross Rob 6rt B. Borsum Director, O&M, TMl B&W Nuclear Technologies GPU Nuclear, Inc. Suite 525 P.O. Box 480 1700 Rockville Pike Middletown, PA 17057 Rockville, MD 20852 John C. Fomicola William Domsife, Acting Director Director, Planning and Bureau of Radiation Protection Regulatory Affairs Pennsylvania Department of GPU Nuclear, Inc. Environmental Resources 100 Interpace Parkway P.O. Box 2063 Parsippany, NJ 07054 Harrisburg, PA 17120 Jack S. Wetmore Dr. Judith Johnsrud Manager, TMI Regulatory Affairs National Energy Committee GPU Nuclear, Inc. Sierra Club P.O. Box 480 433 Orlando Avenue Middletown, PA 17057 State College, PA 16803 Emest L. Blake, Jr., Esquire Peter W. Eselgroth, Region 1 Shaw, Pittman, Potts & Trowbridge U.S. Nuclear Regulatory Commission 2300 N Street, NW. 475 Allendale Road Washington, DC 20037 King of Prussia, PA 19406 Chairman Board of County Commissioners  ;

of Dauphin County -

Dauphin County Courthouse l Harrisburg, PA 17120 1 Chairman Board of Supervisors of Londonderry Township R.D. #1, Geyers Church Road Middletown, PA 17057 Wayne L. Schmidt

Senior Resident inspector (TMi-1)

U.S. Nuclear Regulatory Commission P.O. Box 21g Middletown, PA 17057

~~l- Regional Administrator Region 1 -

U.S. Nuclear Regulatory Commission 475 Allendale Road '

King of Prussia, PA 19406 i

4 Audit Reoort Commitment Manaaement GPU Nuclear. Inc.

Three Mile Island. Unit No.1 Docket No. 50-289 i

1. . INTRODUCTION i

As part of the staff's activities related to improving the management oflicensing basis information, audits of commitment management programs have been or are being performed at eight reactor facilities. The audits assess licensees' implementation of commitments made to NRC and also assess the long-term control of commitments as a follow-up to the issuance of industry guidance for evaluating and reporting changes to commitments made to the NRC.

Three Mile Island, Unit No.1 (TMI-1) was selected as one of eight facilities whose commitment management programs were audited l:y the staff.

The audits and other staff efforts related to managing licensee commitments made to the NRC l

' are intended to improve the (1) identification of important licensee comn itments or other supporting design features or operating practices used by the licensee to justify a proposed change or address design or operational problems, (2) determination of the most appropriate means by which important commitments or other support;ng information should be verified, and (3) determination if the appropriate plecement of the information within the various licensing basis documents associated with the affected facility (i.e., the license or technical specifications,

l. the FSAR, program description documents, or docketed correspondence without formal regulatory controls). The findings from the audits will be used in the staff's development of l recommeridations to the Commission regarding the need for further staff actions in the area of l comm.tment management.

' The audit at TMI-1 was performed by Timothy G. Colbum and William Reckley of the Division of Reactor Projects, Office of Nuclear Reactor Regulation, during the period of March 30 through April 1.1998, and by Timothy G. Colbum during the period of May 28 through May 29,1998.

Additional discussions between the licensee end staff and additionalin-office review of material provided by the licensee were performed from the NRC/NRR offices in Rockville, Maryland. The sudit consisted of interviewing personnel and reviewing procedures, guidance documents, and other documentation related to the commitment management process used by the licensee at TMl-1. Additional reviews of work records, procedure changes, and other documentation were performed to verify the implementation of specific procedures or to evaluate changes made to

! commitments previously made to the NRC.

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ll. VERIFICATION OF LICENSEE IMPl FMENTATION OF PAST COMMITMENTS in order to verify that the licensee effectively implements those commitments made to the NRC during staff reviews related to licensing actions and licensing activities, the auditor selected a sample of commitments made during interactions between the licensee and NRR personnel. The auditor's findings regarding the licensee's implementation of th; selected commitment 2 are desenbod below':

~ The GPU Nuclear, Inc. (GPUN) letter dated 2/10/97 (6710-97-2023), in response to NRC staff's request for information pursuant to 10 CFP 50.54(f), dated October 9,1996, re: adequacy and .

availability of design basis information, made several commitments, four of which were reviewed during this audit. l

1. Develop Engineering Procedure EP-405 to improve the review and update process for j system design basic documents (SDBDs) and the FSAR (fine! safety analysis report).

The auditor reviewed procedure EP-045, Rev.1, " Control of System Design Basis Documents and UFSAR Update Reviews," dated 9/5/97. Ine auditor also reviewed procedure 1000-ADM-7320.01, Rev. 6, " Updated FSAR Document Change Control" which j had been referenced in EP-045. The auditor determined that the licensce had developed

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a procedure as per the licensee's commitment for the review and update process for SDBDs and FSAR updates. The auditor noted, housver, that exhibit 1 of the EP-045 j>

procedure was to contain a flow chart of the process yet instead was a blank page except l for a ncte that the flow chart would be provided at a later date. The auditor determined that the tracking number for this cunmitment had been closed and no other tracking item had been opened to follow up on the flow chart development.' When this observation was presented to the licensee's staff, the licensing engineer acknowledged the observation end generated a CAP (corrective action plan) item to follow up on the flow chart development and entry into the procedure.

The auditor revicwed procedure 1000-ADM-7320.01 and observed that two statements in the procedure appeared to be conflicting. Paragraph 4.1.5 states that a Safety / Environmental Determination and Safd/ Evaluation (SEDR/SE) shall be submitted

- with each PFU (plant FSAR update), however, a statement in paragraph 4.2.1 states that if [an) SEDR/SE is not needed, the originator shall document the basis on the PFU form.

The auditor interviewed the licensee's staff and provided this observation. The licensee's staff indicated that it has always required SEDRs for PFUs but that the confusing requirements would be addressed in a future revision to procedure 1000-ADM-7320.01.

The auditor determined that despite the observations r oted above, the licensee had met the above commitment.

1 1 The apparent inconsistent classification of actions as " commitments" within the licensing organization led the auditors to include some items within the licensing action request (LAR)

V system in the verification even though they were not officially classified as a commitment within the tracking system. The auditors used theirjudgement in the selection of such items and considered v/hether the items would likely be classified as commitments by the NRC str.fror other licensees.

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2. Conduct personnel training on the new FSAR upc%te process procedure, EP-405.

l . The auditor reviewed training record documentation for 250 GPUN employees and the lesson plan for the training on EP-045. The record showed that the employees had been trained in the use of the procedure oer the commitment. One minor observation made to the licensee was that the lessori plan incorrectly listed Rev. O of EP-045 as the current revision of the procedure even thcugh Rev.1 had been issued 2 months prior to the training. Also the date for Rev. O was listed incorrectly as 2/29/97 (not a legitimate date), I vice ma correct date of 4/1/S7.

3. Complete procedure revisions for and training on an improved process for contro: ond updating of calculations and TDRs (technical data report).

l The auditor reviewed licensee procedure no. 5000-ADM-7311.01 (EP-006), Rev. 5, i

" Calculations," dated 9/5/97, training lesson plan 11.2.11.126, Rev. O, " Training on '

Calculation Procedure EP-006," dated 8/7/97, and training record sheets for training j conducted bE, tween 8/7/97 and 11/19/97. The auditor determined that the licensee's L revision 5 to EP-006 and attendant training satisfied the commitment.

! 4; implement an improved corrective action system common to both TMI and Oyster Creek. I I The auditor reviewed the licensee's procedure no.1000-ADM-7216.01, Rev. 3,

" Corrective Action Process," dated 4/1/98. The procedure implemented a new corrective  !

action process (CAP), common to both TMI and Oyster Creek sites. The procedure clearly indicated management's expectations and identified that the CAP process was the primary mechanism for reporting problems but allowed that other methods for reporting problems such as the Ombudsman or the NRC were also acceptable. The auditor was ,

unable to judge the relative effectiveness of the new CAP process with the previous  !

- processes, but it appeared that the consolidation of several different processes into a single process was positive. The auditorjudged that this procedure revision std isfied the commitment.

The GPUN letter dated 8/5/96 (6710-96-2273), contained several licensee commitments in

- response to the staff's Generic Letter (GL) 89-10, " Safety Related Motor-Operated Valve (MOV) l~ Testing and Surveillance," three of which were reviewed during this audit.

- 5. Revise TMI maintenance procedures to ensure valve intemals are evaluated for potential impacts upon stem thrust requ!rements, by use of post maintenance dynamic testing when appropriate.

The auditor reviewed the licensee's corrective maintenance procedure CMP 1410-V-10, I Rev. 32, dated 1/29/98, and was able to determine that the licensca added a note to the proceciure to reflect the commitment and revised sectir. 4.7 of the procedure to address the commitment. The auditor determined that the licensee fulfilled this commitment.

~ 6.- Valve modifications (planned for the 12R refueling outage, fall 1997) to increase the margins of available thrust or torque capability above design basis requirements.

The auditor reviewed several representative design packages related to the above valve modifications including the post modification test results and determined that the

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modifications had been completed as scheduled during the 12R outage and that they satisfied the commitment.

7. Implement MOV Independent Review Toom recommendations. I The auditor reviewed the recommendations contained in the repor1 of the Independent .

Review Team (IRT) relative to the TMl GL 89-10 MOV program. The IRT divided the {

recommendations into Category A recommendations, those considered necessary actions for the successful closure of the TMI GL 89-10 Program, and Category B l recommendations, those considered necessary actions for the improvement of the GL - l 89-10 MOV program and/or for the prevention of similar difficulties in the management of l it or other large programs. The IRT identified 19 Category A and 11 Category B recommendations. The auditor reviewed the licensee's memorandum dated 1/6/98 (6710-97-1519, Rev.1), providing the status of the imple ientation of the recommendations, and the licensee's letter of 12/31/97 (3710-97-2503-1) which provided a' status of commitments 5 7 above. The licensee's 12/31/97 letter stated that the IRT recommendations w6rt 80% complete. A discussion with the licensee's stel; rnembers indicated that the Category A recommendations were completed in June of 1997, but that not all of the Category B recommendations were complete. However, the licensee's .

1/6/98 memorandum indicated that Topical Report 113, " Generic Letter 89-10 Motor Operated Valve Program Description," developed in response to recommendation A2 was stillin the design verification process. In addition, the status of recommendation A16 did not state that comparisons of GPUN dynamic testing requirements against GL 89-10 and GL 96-05 standards and "best"irsdustry practices had been done per the recommendation, nor did it provide results of thoss comparisons, but listed instead a number of improvements that had been made to the GPUN GL 89-10 MOV program.

' The licensee stated that these improvements were identified as a result of the  ;

comparisons. It was not clear from the documents reviewed that all of the Category A recommendations had been completed prior to declaring closure of GL 89-10 in June 1997 as had been the IRT's intent. However, the auditor did not determine that any IRT recommendations would not be met.

The licens3e's annual update of it's Integrated Schedule dated November 7,1994, contained several commitments, three of which were reviewed during this audit.

8. Conduct augmented inspections to detect erosion / corrosion in two-phase systems during the 12R and 13R outages.

The auditoi reviewed the licensee's memorandum dated 10/9/97 (E520-97-035),

providing the results of flow accelerated corrosion (FAC) inspections conducted during the 12R outage. The auditor also reviewed the licensee's specification SP-1101-12-110, L  ; " Nuclear Safety Related Pipewall Thinning Inspections, Specification For TMI-1 l Erosi.in/ Corrosion Program," Rev. 7, dated 2/6/97. The licensee initiates Engineering ,

Evaluation Reports (ERs) if a components measured minimum wall thickness falls below li

! 87.5 percent of its nominal thickness. Further engineering analysis is then required to I determine the components continued acceptability for continued service. The auditor determined that the licensee has met this commitment with respect to the 12R scheduled j inspections and has' additional!nspections scheduled for 13R and 14R.

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1. j L, 5 L. Upgrade the reactor building tendon surveillance program procedure to meet Regulatory Guide 1.35 Rev. 3 guidance.

The auditor reviewed GPUN procedure SP 1301-9.1, Rev.13, "RB [ reactor building)

-. Structural Integrity Tendon Surveillance," dated 1/24/95, and GPUN procedure SP 1301-8.1, Rev.14, " Reactor Building Concrete / Liner Inspection," dated 10/11/95. The auditor determined appeared from the review of the procedure revisions that the licentse met this commitment.

10. Evaluate options for non-intrusive test of check valves to meet ASME Section XI requirements and provisions of GL 89-04, 4 The auditor reviewed GPUN memorandum dated 2/23/94, " Closeout of 11R Open Item for  :

Scope Definition of Non-Intrusive Check Valve Testing," GPUN memorandum dated 10/4/95, " Check Velve Non-Intrusive Testing Results in 11R," and GPUN memorandum dated 5/21/96, " Minutes and Action itemr From IST Check Valve Meetings." The 2/23/94 memorandum provided the scope definition for non intrusive check valve testing and the

. 10/4/95 memorandum provided the results of the 11R non-intrusive testing. The 5/21/96 i memorandum provided the results of the 5/1/96 and 5/14/96 meetings held to determine '

the best method to verify operability of several IST check valves that cannot be tested at their accident design flow rate. Several test recommendations and action items resulted '

from these meetings. - References to the ASME Code requirements were included in the action items and background information to ensure Code requirements were met. Based on a review of the above documents, the auditor determined that this commitment had -

been met.

Additional licensee commitments were audited as listed below: -

11.' NRC letter dated 11/7/96 transmitting the results of NRC Inyution 96-08 documented the licensee's commitment to add 28 ASME Class 2 & 3 relief valves and four decay heat removal [ pump) casing vent valves to the IST Program for TMI-1.

The auditor reviewed GPUN memorandum dated 5/15/98, " Review of TMI-1 response to

. GL 87-06," GPUN memorandtmi dated 12/15/97, "lST Program Scope Review," and GPUN surveillance procedure SP 1300-4H, Rev. O, "lST of ASME Class 2 and 3 Relief Valves." The auditor determined from a review of these documents that the 28 ASME Class 2 and 3 relief valves and four decay heat removal (pump] casing vent valves had been added to the IST program per the commitment. Therefore, the commitment has been met.

12. The licensee's June 23,1997, letter (GPUN 6710-97-2283) in response to NRC Inspection report 96-201, dated April 15,1997, committed to revise abnormal transient procedure (ATP) 1210-07, "Large Break LOCA Cooldown" to limit LPI (Iow pressure inje.ction) and BS (building spray) flowrates to ensure adequate NPSH without credit for containment overpressure.

The auditor reviewed the licensee's procedure no. ATP 1210-7, Nov. 25, "Large Break LOCA Cooldown," dated 4/15/98, calculation no. C-1101-210-E610-011, Rev. O, "LPI and BS Pump NPSH Available From the RB Sump," dated 6/2E,/97, and SE I

. (safety \ environmental determination and 10 CFR 50.59 review) no. SE 000212-032,

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" Decay Heat and RB Spray Pump Flow Throttling Criteria for RB Sump Recirculation,"

dated 7/15/97. The auditor determined that the licenscs satisfied the commitment with that revision to the procedure.

13. The licensee's letter dated January 12,1993, (6L20-98-20004), which transmitted the  ;

results of the steam generator inspections performed during the TMI-1 Cycie 12 Refueling l Outage, committed to provide the results of the pulled tube analysis including laboratory l leak and burst testing by June 1,1998.

The licensee provided the results of that analysis by letter dated May 19,1938 (GPUN -

1920-98-20256). The auditor verified that this letter fulfilled the licensee's commitment.

14. In the licensee's March 26,1997, response to LER (licensee event report) 96 001-01, the licensee committed to revise procedure AP1002 to permit testing of ES breakers.

Admin'.ettative controls would be established in procedures implementing SQUG (Seismic Qualification Utility Group) methodology in the seismic verification process to confirm seismic operating performance.

The auditor reviewed GPUN procedure AP1002, Rev. 81, " Rules for the Protection of Employees Working on Electrical and Mechanical Apparatus," dated 3/20/98. The auditor determined that the procedure was revised to include the administrative controls discussed above with revision 80 to the procedure. The auditor determined that the licensee met this commitment.

111. LICENSEE PROGRAMS FOR MANAGlNG (CHANGING) COMMITMENTS The primary focus of this part of the audit is to assess the licensee's programs and performance related to implementing controls for modifying or deleting commitments made to the NRC. The staff's interest in this matter is related to how changes to commitments (modifications or deletions) are evaluated and how the NRC is informed of commitment changes that have safety or regulatory significance.

Following the accident at TMI-2 and in support of the restart of TMI-1, the licensee created a mainframe computer based tracking / record system called the Commitment Tracking System (CTS) in 1989 The CTS included commitments made to the NRC during or after 1979 and did

. not capture those items preceding the TMI-2 accident, including commitments made during initial licensing. The CTS was used to record and track the status of commitments until 1994 when the licensee transferred the function to a network server based information management system using Foxpro software. The system was entitled the Licensing Information Tracking System (LITS). The licensee updated LITS in 1998 to a Lotus Notes based platform. It should be noted that the primary focus of each of these systems was to ensure that commitments were properly implemented and that the in:plementation was documented in the tracking system.

The current LITS system provides improved search capability for commitments and affected plant equipment and procedures. The records from the CTS and previous LITS databases are available on the same computer system as the updated LITS. The licensee has incorporated a variety of plant tracking systems onto the Lotus Notes applications and can search the databases for related actions and status. Actuallinks between the various databases are not currently incorporated into the licensee's information management system.

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. 7 l The licensee's current process for identifying and tracking commitments works by first assigning -

l actions described in written communications with the NRC to the responsible organization by the ,

lasuance and acceptance of a Ucensing Action Request (LAR). The LAR includes a description l of an action to be taken and a schedule for its implementation. The LARs are tracked by the licensing organization. Changes to schedules are communicated to the NRC if the completion is extended beyond the date specified in the correspondence with the NRC. Upon completion and closure of specific LAR items by the responsible licensee organization, licensing personnel j decide whether or not to classify the item as a " commitment". The LAR form (screen) has fields

' (yes/no and descriptions) that are used to record the assigned licensing engineer's determination regarding the classification of an action as a commitment or not a commitment. The licensee's definition of a commitment (as found in Regulatory Affairs instruction 94-01(TMI), " Licensing information Tracking System," Rev.1, June 14,1995, and presented during discussions with -

licensing personnel at the beginning of audit)is:

(Onaoina) Commitment - a documented obligation, in written format, made either by the company or through an uncontested imposition by a regulatory agency that either established requirements or promises actions to be performed.

The guidance in the instruction was, in general, considered to be the applicable guidance document for the current system. The LITS system included coding for commitment status and used language such as active / inactive and open/ closed. The definition of the commitment status terminology and the relationship between the current terms and the previous terminology for the 2

CTS were not well defined . The commitment codes from the LITS instruction are as follows:

Onaoina commitments (O) are those ACTIONS / PROHIBITIONS with which continual compliance is required by regulations, or procedural steps which serve to comply with the underlying rules or legal requirements.

Refuelina outage commitments (R) are ACTIONS which are applicable only du:ing refueling outages.

Unscheduled outage commitments (U) are ACTIONS which are applicable during the next unscheduled outage.

2 The definitions of commitments in the CTS (from Licensing instruction PWR-101, Preparation of Commitment Tracking System input Data," Rev. 2, (9/22/89) were:

Active Commitment: one in which a specific implementation or submittal date must be met. Active commitments are eventually resolved to another type.

- Onaoina Commitment: one in which cantinual compliance must be ensured. In the event that an ongoing commitment is later 6termined to be no longer required, the ongoing commitment is resolved to an historicalstatus.

Historical Commdment: one in which no further action or consideration is required, and the commitment h4.4 been fully implemented. These commitments are maintained to provide historical documentation of GPUN addressing allissues.

ProhEL,c Commitment: one in which the use of an action, material, etc. is not allowed.

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v I 8 The auditors had dhcussions with different licensing engineers sad it appeared that different I criteria were being applied to decide if actions should be classified as commitments. In genenal, only these items that involved ongoing programs or procedure changes ware deemed to be

!- commitments. "One-time actions" are closed upon completion of the I.AR item and although

recorded and serrchable using LITS, would not be identified during any subsequent search that was limited to items classified as commitments. The classification of items resulting in i

. procedure changes appeared to sometimes be classified as a commitment, per above discussion l of ongoing items, and sometimes be classified as not being a commitment, the logic being that I the assigned action was to change the procedure and that changing the procedure was a one- l time action.' Likewise, hardware or design changes are generally not classified as commitments. i Once completed, the licensee depends on the design process to maintain and, if necessary, '

! control subsequent changes to the commitment and affected equipment.  ;

if an action closed within the LAR process is classified as a commitment, entries are made into the appropriate fields in the LITS record. The LITS system includes information such as the a

^ ffecteo procedures, source documents, and personnel associated with the disposition of the item. Searches can be performed on fislds or text within LITS and, if used, could assist licensing or other line organizations in investigating the possible impact of proposed actions on previous commitments made to the NRC. Improved consistency in classifications and a review of previcus classifications would be necessary to provide confidence that such searches actually identified commitments and affected procedures.

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. A formal procedure or guidance document daes not govem the evaluation and reporting to the

. NRC of changes to commitments, if the LAR item has not been completed, it is highly likely that

- necessary changes to the committed schedule or action would be identified by the responsible personnel and revisions to the associated LER, NOV iesponse, or other correspondence would .

be transmitted to the NRC. Another tool used to track the status of the implementation of actions described to the NRC in various correspondence is Integrated Schedule or Long Range Planning Program (LRPP) that is periodically submitted to the NRC in accordance with License Condition flo. 2.c(9) of the operating license for TMI-1 (DPR-50). The LRPP includes three categories of major projects (A, B, and C) witu each category having a defined mechanism, from prior NRC approval to notification of changes in annual update, for interacting with the NRC staff on the actions and schedules. Many of the items in the LRPP (ABC project listings) pertain to

commitments the licensee has made in response to generic communications from the NRC. The items listed in the LRPP as Category A items (currently there are none) are those that the licensee cannot change without prior NRC review and approval. These items would be classified

as requirements in the iicensee's tracking system and would not be identified as commitments.

Category B and C items frem the LRPP may be changed without prior NRC review and approval l in accordance with license condition 2.c(9), but would be identified in the next annual updata of l - the report. Items in the report are further classified within each of the three categories. An

( "NRR" classification indicates that the item is necessary to meet NRC requirements and may or L may not be classified as a commitment by the licensee, These are activities that must be carried l . out to fulfill a specific NRC requirement, or have been committed to the NRC by the Campany, or i are activities thnt if not accomplished, would result in an NRC non-compliance even mough the specific activities are not required by the NRC. If the activities are considered commitments made by the Company, then they would be tracked under the LITS system as such. The auditors consider the Integrated Schedule contained in the LRPP to be s., importart part of the overall 1

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. implementation t . ius and schedule for those pending commitments categorized within the ABC

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project listings. '

' The licensing prsonnel interviewed stated that letters are (or would be) used to report changes to commitments that had been implemented when such changes are identified. This was said to l happen infrequently. General guidance (Step 4.1.7) in Procedure 1000-ADM-1291.01, Revision l

! 13, " Safety Review Process," states that: i The preparation and review of Safety Determinations and Safety Evaluations should also include consideration of other regulations and commitments regarding safe plant operation. While this procedure requires review of the Safety Analysis Report, Operating License, Technical Specifications (Appendix to Operating License), and ISFSF Certificate

' of Compliance, consistent with the requirements of 10 CFR 50.59, (10 CFR 72.48 for the OCNGS ISFSF), management commitments should be considered in determining the effect on nuclear safety or safe plant operation (i.e., regulations and commitments to maintain safa plant operation that were detailed in correspondence to the NRC in .

response to NRC Bulletins, inspection Reports, Notice of Violations, etc.) Although not I required by 10 CFR 50.59 or 10 CFR 72.48, these management commitments should be ,

preserved or their safety significance considered when a change to the commitment  !

occurs, if the subject matter has the potential to affect commitments, then interdisciplinary review is suggested.-

The personnelinterviewed stated that the use/ implementation of the above recommendation for <

commitments (not required by the. procedure because of incorporation into the FSAR) was done i on a case-by-case basis if the evaluator recognized that a proposed change affected a commitment previously made to the NRC. Documentation of the change would be pursuant to  !

the procedure if a safety determination / evaluation was performed but would likely not be

- documented, other than in accordance with processes for changing design documents or procedures, if the commitment change was not svaluated in accordance with Procedure 1000-ADM-1291.01.

Procedures are not annotated to mark changes resulting from regulatory commitments. The licensee personnelinterviewed stated annotating procedures may be pursued as a long-term enhancement as procedures are converted to a different word processing system. The procedure

. revision process may include documenting on the procedure change request (PCR) form that a proposed change is due to a regulatory commitment. Subsequent changes to the portion of a procedure implementing a committed action may be 16 cognized if the procedure writer identifies a previous PCR that mentions the commitment.

IV. EVALUATION OF COMMITMENT CHANGES in order to verify that the licensee effectively controls changes to commitments made to the NRC,

. the auditor reviewed annual updates to the long range planning program (integrated schedule),

, , . reviewed the 12/11/97 update of schedules to completion of open items from inspection report IR g 50-289/96-201 (engineering design inspection), dated 4/15/97, and reviewed the licensee's 9/29/94 letter, C311-94-2136, providing the status of corrective action taken for violation 91 '

- 001. Given the small number of items classified as commitments at TMI-1 and the lack of a j searchable information system to identify those commitments that have been revised, the auditors identified and reviewed only one commitment change. As described in the 9/29/94 l

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e 10 letter, the licensee changed its commitment to replace a bent valve stem on the high pressure injection discharge isolation valve MU-V16A, as committed to in responsw to the above violation.

Subsequent surveillance test results and engineering evaluation determined that the replacement was unnecessary. The licensee committed to continue to monitor the valve conditinn through visualinspections in acconlance with GPUN surveillance procedure SP 1300-3H. The auditors determined that the licensee properly evaluated and reported this change in commitment.

' V. LICENSEE SELF-ASSESSMENTS (if anolimMM in preparation for the NRC audit, the licensee performed a self-assessment of the commitment managen3nt system at TMI-1. The self-assessment had been completed but the report was not yet issued at the time of the NRC audit. The auditors discussed the self assessment with licensing personnel and determined that it was primarily a comparison of the licensee's process and the process described in the NEl guideline dated December 1995. The self-assessment credited the procedural step in 1000-ADM-1291.01, Safety Review Process, for ensuring that ';

proposed changes to commitments are reviewed and documented. A previously discussed, the auditors expressed concems that the licensee's system foi dessifica' an and traceability of commitments may not support the evaluation recommended in the procedure. The licensing personnel stated thst a likely recommendation from the self-assessment would be a consolideilon of guidance related to commitment management into a single procedure (likely to be 1000-ADM-1216.03, Regulatory Correspondence Control). Other recommendations involved moving the licensee's commitment management system closer to the process described in the NEI guidance document. An item (CAP Tig8-206) was entered into the licensee's corrective action program to document the recommendations and suggestions identified by the self-assessment.

The licensee's preliminary audit findings indicated that the current GPUN process for commitment control is incomplete, and lacking appropriate guidance to assure the adequate management and change controls and that prior commitments were considered in their dealings with the NRC.- The licensee determined that they met the NEl guidance in a number of areas but did not in some others. Some examples of where the licensee determined it did not meet the NEl guidance included: 1) "there is r.:: means to distinguish between regulatory commitments and voluntary enhancements..." ; 2) '1ack of commitment change guidance precludes the consideratim cf periodic evaluation of outstanding commitments and the manner in which they have been implemented..."; and 3) " no guidance is provided for changing commitments to regulatory agencies. It is only through the... safety review program that most commitrr,ent changes receive an appropriate review of safety significance and consideration of a need for

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NRC approval." The licensee proposed several recommendations to bring the commitment

. management program in line with the NEl guidance.

VI. CONCLUSIONS /

SUMMARY

The auditors found that the commitment managem3nt system for TMI-1 is strengly geared to ensuring that actions are assigned snd completed within established schedules. The ability to evaluate subsequent changes to commitments is limited by both the lack of either direct  :

i traceability of commitments within affected documents or an information system that could be  !

widely used and contains reliable data on commitments. Problems were identified in the area of j consistent classification of actions as commitments. However, except for the minor observations  !

~n oted above, the licensee met all of the commitments reviewed by the auditors and no evidence was found that inconsistencies in classification affected the implementation of commitments.

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