ML20236P271

Provides Status of Corrective Actions Taken as Result of Recommendations Contained in SALP Rept 50-289/86-99. Attachment 1 Provides Details on Corrective Actions Taken & Attachment 2 Discusses Activities Taken

ML20236P271
Person / Time
Site:	Three Mile Island
Issue date:	11/09/1987
From:	Phyllis Clark GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
5211-87-2185, NUDOCS 8711170220
Download: ML20236P271 (13)

Text

- _ - _ _ _ ,_ .-.

h0 ,

GPU Nuclear Corporation 3 Nuclear  ;;;,omg -

'Middletown, Pennsylva'nla 17057 o191 717 944 7621 l

, ' TELEX 84 2386 Writer's DI. rect Dial Number:

November 9, 1987

-5211-87-2185 k

U.S. Nuclear Regulatory Commission .I Attn: Document Control Desk Washington, DC 20555 i

Dear Sir:

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

Operating License No. DPR-50 Docket No. 50-289 ,

Systematic Assessment of Licensee Performance (SALP) )

References:

(1) T.E. Murley letter to H. D. Hukill, Systematic Assessment of Licensee Performance (SALP); Report No. 50-289/86-99, dated January 5,1987.

(2) GPUN letter, P. R. Clark to T. E. Murley, Response to SALP Report 86-99, dated April 1,1987.

The purpose of this letter is to provide the status of corrective actions taken as a result of the SALP Board's recommendations that were provided in Reference 1. Reference 2 contained the GPUN TMI-1 response to Reference 1. ,

In addition, we would also like to take this opportunity to provide j information on other actions taken and our performance over the last year  !

which may be useful to the SALP Board in their next assessment of Three Mile Island Unit 1 (TMI-1).

Attachment 1 provides details on the corrective actions taken as the result of the last SALP Report (Ref.1).

Attachment 2 discusses some of the other related GPUN activities taken and our performance over the past year.  !

Sincerely, 8711170220 871109 R

ADOCK0500g9 ((, p P. R. Clark President PRC/DVH/spb:1001 A  !

Attachments cc: W. Russell G. Edison [g R. Conte >

l. g GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation

Docket No. 50-289  !

?

r-L ATTACHMENT 1 GPU NUCLEAR THREE MILE ISLAND - UNIT 1 UPDATE-TO SALP REPORT NO. 86-99 RECOMMENDATIONS i;

'I j.

1 l  ;

i l

November, 1987

l i

FUNCTIONAL' AREA: Technical Support BOARD RECOMMENDATION:

Undertake a self-analysis to determine the causes for inconsistent performance in this area.  ;

STATUS:  !

In July 1987, GPUN initiated a program to perform a scif assessment in the technical support area looking for.both areas of strength and weakness and any supportive information leading to inconsistencies in performance. The scope '

of the assessment includes the total technical support organization, i principally the plant engineering functions within the GPUN Plant Divisions and the Technical Functions Division. This self assessment is looking at both strengths and weaknesses of these organizations and the manner in which the organizations interact with the plant operation and maintenance functions.

The objectives of the self assessment are to factually establish areas of inconsistent performance, if any, and to provide a basis for management focus on any of the weaker performance areas. This program was reviewed with the TMI-1 Senior NRC Inspector and Region I Manager on July 2,1987. Phase I of the program, which includes development of the approach and the initial data collection / preliminary evaluation, is about conplete. Phase II, consisting of screening the initial results, looking for areas of further analysis, conclusions and development of a corrective action plan, has been initiated.

It is anticipated Phase II will be completed in 1987. Phase III and IV will be continued into 1988.

1 l

l l

4 1 -1

FUNCTIONAL AREA: Assurance of Quality j BOARD RECOMMENDATION:

i (1 ) Continue efforts in correcting p'rocedure adherence and procedure adequacy ,

proolems.

(2) Independently meet with the NRC to discuss the revised safety review process and corrective actions of the Procedure Compliance Task Group.

STATUS:

(1 ) Management maintains strong emphasis on procedural adherence and adequacy. Initiatives have been made to strengthen this area and make continued improvement. The Quality Assurance Department continues to monitor and address procedure compliance. Item 2B below addresses actions from the Procedure Compliance Task Group (PCTG). This item continues to have management attention to bring the number of compliance problems down. We believe the long term implementation of the PCTG recommendation will improve our procedure compliance. We will continue to follow and monitor this item.

(2) A. On February 12, 1987 GPUN management met with Region I management at the Region I office to discuss the revised GPUN technical and safety review program. Tnis meeting resulted in three commitments by GPUN.

These commitments as identified in Inspection Report 87-04 were:

1) The licensee's Technical and Safety (T&S) review process will be revised to assure an explanation of negative answers to the questions on this initial screening process delineated by first form of licensee's two-step process.

2) The licensee will continue to evaluate the effectiveness of procedure changes using the new T&S review process.

3) More guidance was to be issued by the licensee, especially in the area of what constitutes a " licensing basis document."

The status of these three items is:

1) GPUN corporate procedure 5000-ADM-1291.02, Rev. 3 was issued August 25, 1987 which incorporates the requirement to explain 4 negative answers on the first form. I

2) GPUN has reviewed the effectiveness of the technical and safety review process. Our reviews to date indicate that the procedure is meeting the intended purpose. However, we have taken actions to enhance the quality of safety reviews. These actions include a revision of the Corporate Procedure to require explicit statements for negative responses on the Safety Determination form and development of guidance with respect to definition of ,

Licensing Basis Documents, j 1-2 l

i

'f

3) -Extensive discussions on what constitutes a " licensing basis documelit" have taken place. Thi:3 includes in-house, with the 4 industry, and legal counsel. The GPUN position is essentially _i' established and is in final review. The schedule to disseminate this' guidance to the reviewers is within 30 days.

(2) B. At the same February 12,'1987 meeting, GPUN summarized the. results of '

the Procedure Compliance Task Group effort and reported the status-of implementing the group's recommendations. The current status of the recommendations is that six of the seven short term recommendations i have been completed. The remaining item is being worked on and wi'll be completed in 1988.

Of the seven long term recommendations, one has been completed. The remaining six are actively being pursued. Several of the six should be completed by the end of 1987 with the others completed in 1988.

I l

1 -3

Docket No. 50-289 I

l 6

i l

ATTACHMENT 2 .

l

-t GPU NUCLEAR l THREE MILE ISLAND - UNIT 1 EXAMPLES OF GPUN/TMI-1 ACTIONS AND PERFORMANCE DURING CURRENT SALP PERIOD I

l i

j i

l j

l November,1987 l

l l

l 1

p l l' l l

C_ _ _ _ _ _ _ _ _ _ . _ __

j

L .,

[  !

l 'GPUN is able to evaluate performance based upon input from NRC, INP0 and L; comparison to industry standards. GPUN is constantly striving to learn end H improve from this avaluative process. The. following represents efforts which l' we believe illustrate this ' point and 'are relevant to the .TMI-l SALP evaluation.

l l l '. Plant Operation p

A. . At the start of this SALP period, TMI-l was shutdown for the start of

.the Cycle 6 refueling outage (6R). Key dates for the outage were: j

• October 31, 1986 - The plant commenced a planned shutdown for the l Cycle 6 refueling outage (6R). Startup from the outage was i scheduled for March 21,1987 (on the grid). i

• March 20,1987 - The plant (TMI-1) proceeded to heatup as the 6R outage was' nearing conclusion.

• March 22,1987 - An Integrated Remote Shutdown System test was successfully completed.

• March 23,1987 - The reactor was taken critical and low power physics testing commenced.

• March 24, 1987 - TMI-l was placed back on the grid and the 6R outage was declared over.

SUMMARY

OF 6R OUTAGE The 6R outage contained several major work items. In addition to the refueling work, other work included Reactor Building Integrated Leak Rate Testing, OTSG Inspection and Repair activities, OTSG Emergency Feedwater Nozzle replacement, M0 VATS testing of motor operated valves, Appendix R work, and the Heat Sink Protection System. Successful con >pletion of this major outage was accomplished by close coordination of the different'GPUN Divisions.

Specifically, the following items were the instrumental parts of this close working relationship.

• During the shutdown process, TMI-l utilized off-shift personnel to perform major surveillance tests while the on-shift crew concentrated on the plant shutdown /cooldown.

• The first item of the outage was to conduct the containment Integrated Leak Rate Test (ILRT) in the "as found" condition.

Although this test failed, it was redone successfully in an "as left" condition.

• By performing this ILRT as the first activity in the outage, we were able to take advantage of this time to allow for decaying radiation levels in the containment. This contributed in a lowering of the man-rem exposure.

2-1

i , 1

• The outage was scheduled for' 5 months. The pace of activities was ,

demanding but appropriate. The results proved the schedule was l commensurate with the scope of work.

• Assigning a dedicated shift technical advisor to act as a single point of contact beteen Operations and Engineering personnel foi* l the Heat Sink Protection System modification was an initiative that proved very beneficial. j 1

• An integral part of the outage was a cautious, planned approach to  !

the work which entailed dry runs where appropriate. Thir resulted l in smooth flow of work and an overall man rem exposure below that I which was originally predicted. )

I

• The extensive startup prerequisite list resulted in a smooth startup from the outage.

All of these items coupled with management attention resulted in a well paced, successful outage.

B. The professionalism of our control room operators continued to be high. Along with this, TMI-1 now has six control room operators who I are qualified as senior reactor operators which provides an.added experience level on shift.

C. On June 12, TMI-1 commenced a plant shutdown to replace both letdown coolers. The transition into and out of the letdown cooler replacement outage was relatively smooth and free of major equipment problems. The success of this outage was due to the good pre-planning and staging of material . The welders assigned to the job were chosen based on their proven competence and did an excellent job the first time. The comfort of the work area was improved by use of temporary air conditioning. The pace of activities was appropriately controlled which indicated our proper regard for nuclear safety. This was so despite the urgency to return TMI-l to power operation for power demand reasons. The plant was restarted June 27, 1987.

D. TMI-1 continues to have a high availability factor. Excluding the 6R

' outage and letdown cooler outage, TMI-1 has been shutdown for less than 2 days through the end of September 1987. Including the outages, the availability for the year through the end of September 1987 is i 63.3%. {

2. Licensing Activities A. GPUN completed a reorganization in June 1987 which established the Planning and Nuclear Safety Division. This is a relatively small, l highly focused division with the charter of improving safety. The

, groups within this division are nuclear safety, licensing and L planning. The establishment of this division reflects on GpVN's commitment to Nuclear Safety and improvement in this area.

l 1

i f

2-2

1 B. Periodic meetings were held between representatives of GPUN Licensing and'the NRC Project Manager to discuss the- status of licensing activities. The dates of these meetings were:

December 8,1986 February 5,1987 j March 11,1987 j April 24,1987 l May 21,'l987 i June 10,1987 j July 8,1987 l September 3,1987 October 9,1987 4

These meetings have proven to be vnry successful in terms of  ;

communicating the status of issues, exchanging priorities /needs, and  ;

expediting actions as appropriate. The NRC has recently indicated the j industry average time to issue a License Amendment is six months from the time the NRC receives a Technical Specification Change Request. '

For TMI-l this is four h.anths which reflects positively on both the NRC and GPUN's overall management of thJse important licensing issues.

On June 9 and 10,1987, the new NRC Project Managers for TMI-1 and Oyster Creek visited TMI-1 for a tour of the plant. Also on .

July 16 and 17, the TMI-1 Project Manager visited the GPUN Parsippany .

of fice. {

On July 16, 1987, the new NRC Region I Administrator conducted an [

extensive 5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> inspection of TMI-1.

l C. GPUN remains active in Industry Activities / Committees to improve  !

Licensing and Nuclear Safety performance. This has improved our ,

understanding of the Safety Review Process. It has particularly {

enhanced our work on Tech. Spec. simplification and great progress has  ;

f been made in this area with the B&W Owners Group (BWOG).

Technical Activities 3.

A. Throughout the year every opportunity has been taken to meet with the NRC to better explain our technical analysis / basis and operational occurrences. The dates of some of these meetings with the NRC, NRR and Region I were:

• February 4,1987 - A meeting was held between representatives of GPUN and the NRC to discuss Reactor Coolant Inventory Trending System (RCITS).

• February 5,1987 - A meeting was held between representatives of GPUN and the NRC on a fire protection exemption for manual actions.

• February 12, 1987 - A meeting was held between representatives of .

GPUN and NRC Region I management to discuss the revised GPUN Technical and Safety Review Program and the results of the GPUN task

• force on procedure adherence.

l 2-3 I ,

N - __ _- _ _ _ _ - - - __ _

i

• February 24, 1987 - A meeting was held between representatives of l GPUN and NRC Region I management to discuss'the SALP Report No.

86-99.

• March 10,1987 - A meeting was held between representatives of GPUN and NRC Region I management to discuss the status of GPUN EQ activities as a result of NRC Inspection 87-01.

• May 21,1987 - A meeting was held between representatives of GPUN and the NRC to discuss new information on OTSG as a result of the tubes pulled during the 6R outage.

• June 10,1987 - A meeting was held between representatives of GPUN and the NRC to provide a status report of the NRC ongoing inspection of the GPUN Technical and Safety Review Program.

• August 24, 1987 - A meeting was held between representatives of GPUN and the NRC to discuss Technical Specification Change Request No.112, Revision 1 (Radiological Effluent Tech. Specs.).

• September 10, 1987 - A meeting was held between representatives of GPUN and Region I to discuss the status of GPUN's EQ program which included completion of previously specified performance requirements. .

• September 10, 1987 - A meeting was held between representatives of GPUN and the NRC to discuss the status of work on Appendix R and ,

HVAC systems. I B. GPUN is very active in the BWOG activities. We have.provided significant input in terms of chairing various subcommittees and are highly involved in all issues. This has resulted in the completion of l the development of the Safety Performance Improvement Program (SPIP) i which is an extensive effort to improve performance. j C. Looking at the technical support provided to the plant throughout the year, it becomes evident that this area is effective as evidenced by 1 the overall good technical support involvement for and during the 6R j Outage and startup, involvement and support of the letdown cooler i outage and continued support of plant operations. The above stated i involvement in meetings and BWOG activities also contributes to the  !

effectiveness of this area. '

D. The engineering items identified during the NRC PAT I and II l inspections and the Readiness Appraisal Team Inspection have all been addressed. Actions to resolve the items, where required or appropriate, have been taken and completed. j We have used the PAT style approach to review some of our other work and believe it has helped improve our engineering work.

l l

2-4 i

4. Emergency Preparedness Several key items were accomplished in this area throughout the year.

These include:

• On November 5,1986, the 1986 annual Emergency Plan drill was  ;

conducted successfully. i

• The 1987 TMI annual exercise was a full scale exercise that was conducted successfully. All state, county and municipal governments observed by FEMA fully participated in the exercise.

• A major revision to the Corporate Emergency Plan has been undertaken and is near completion. This revision takes into account NRC j comments in addition to changing conditions at Unit 2. GPUN met '

with Region I on June 19, 1987 to discuss the proposed revision. j

• Unannounced shift and quarterly drills have been conducted to  !

thoroughly test the availability and readiness of emergency response '

personnel.

• Utilization of the TMI Replica Simulator has been used for drill scencrfo development. It is expected that the simulator will be used for drill conduct starting in 1988. l

• Emergency Plan Training Requalification Program has had a thorough job task analysis conducted which had active input from key emergency response personnel, Emergency Preparedness Department and Training and Education Department, all of which culminated in a more effective requalification program.

l

• A site has bee:1 identified for the new TMI Remote Assembly Area  !

which provides a facility away from the predominant wind patterns  !

and affords better protection for site evacuees. j

• Significant refinement has been made to the offsite dose assessment  !

process to include increased reliability and accuracy both in the '

form of software and hardware changes.  ;

5. Training  ;

i GPUN's commitment to training continues to be an important factor in the operating of TMI-1. Although training is usually thought of as licensed operator training, this category involves much more. GPUN has INP0 accredited training programs in the areas of-

a. Auxiliary Operator ,

b. Reactor Operator

c. Senior Reactor Operator

d. Shift Technical Advisor

e. Rad. Con, j

f. Electrical Maintenance 9 Mechanical Maintenance

h. I&C Maintenance

1. Chemistry

j. Technical Staff and Manager 2-5 l

Additionally, our corporate training has programs for engineers, shift technical advisors and managernc'it. In the past year, a large percentage  :

of managers and supervisors have ettended an extensive GPUN Teamwork and Leadership Program. This program builds on the concept of communication across division / department lines and individual accountability to foster ;

the team concept. GPUN firmly believes in this program and that it will '

assist in improving our performance.

The TMI-1 plant specific simulator was placed into service this year. The simulator is now an integral part of training and was used as part of the annual requalification examination.Previously each crew only had one week of training on the plant simulator at B&W. Now each crew has 55 to 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> per year on the TMI plant specific simulator. GPUN emphasis is on the crew working as a team. This additional time allows for each crew to simulate plant conditions and improve on the team concept.

On March 12, 1987, GPUN completed the administration of the annual requalification examinations for licensed operators (R0 and SRO). These examinations were audited by the NRC and the NRC did substitute NRC questions in about 10% of the examinations. These examinations were the culmination of an extensive training program which emphasized new modifications installed during the 6R outage. In addition to classroom sessions, this training also included plant walk-throughs and easy to read handouts. This aided the operators in becoming familiar with the new modifications.

The revised Operator's Licenses rule, Part 55 became effective in May 1987. GPUN has implemented this revised rule.

6. Security and Safeguards The Security Department has taken the following actions to enhance the security program at TMI-1 since their last SALP report:

i

3. Installed a new Perimeter Intrusion Detection System which provides a '

high level of assurance that unauthorized personnel and/or intrusion attempts would be detected and appropriate response initiated.

b. Installed new search equipment in personnel processing center.

Realigned search equipment to enhance personnel processing and increase capability of detecting explosive devices.

c. Eliminated all contract security officers and increased GPUN site protection force.  ;

I l

1 I

l l

1 2-6 \

[ a.i l a, d. In~ addition'to Training and Qualification Program. requirements, a j Strategic Planning. Team Training Program has been implemented. q Instructors for this program have been trained in Strategic Reaction s a Team by:Essex Corp. in Gainsville, Georgia; Response' Team at Pensville ]

Police Dept. and sponsored by the Greater Pittsburgh Police Dept. j

. Association; and Hand Gun Retention Program by Smith and Wesson Corp.- i

e. Implemented 10CFR73.67 (FBI Criminal Background Checks). Over.2300 personnel who access TMI have been fingerprinted in conjunction with this program,

f. Submitted Revisions 22, 23 and 24 to the Security Plan. Revision 24 significantly. upgradas the Personnel Security Screening requirements.

The new screening requirements are essentially those approved by NUMARC.

2-7