ML20245H674
| ML20245H674 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/14/1989 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.1, TASK-TM C311-89-2084, NUDOCS 8908170237 | |
| Download: ML20245H674 (7) | |
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Route 441 South Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Nurnber:
Aucrust 14, 1989 C311-89-2084 U.
S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555
Dear Sir:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 GPUN Response to Inspection Report 89-80 NRC Special Inspection of TMI-1 Emergency Operating Procedures This is in response to the NRC's Inspection Report (IR) 89-80, dated July 7, 1989.
IR 89-80 pertains to-the NRC's inspection ~of TMI-l's Emergency Operating Procedures (EOPs) conducted onsite
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March 6-17, 1989.
The report requested a response, within
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30 days, to the comments contained in the report.
This letter i
provides GPUN's response with commitments toward resolution of the NRC's comments.
An additional week for responding was provided by the NRC as discussed with the resident inspector's office on July 21, 1989.
We appreciate the fact that the inspection team's appraisal 1 reflected favorably upon GPUN's implementation of the TMI Action Plan, NUREG 0737 item I.C.1, "EOP upgrade", for TMI-1.
A list of comments and suggestions, characterized as minor by the inspection team, is included with IR 89-80.
We do not believe any of the conditions noted in the NRC's report would result in undue operator burden or incorrect action.
Certain procedure changes recommended by the NRC have already been incorporated and steps have been initiated to disposition all of the comments.
Additional procedure changes that are identified will be made as part of the biennial review process.
All actions that are found to be appropriate regarding the procedure changes that affect the Abnormal Transient Procedures (ATPs) will be completed by December 31, 1989.
Changes to any of the other EOPs will be completed no later than October, 1991 in accordance with the biennial review schedule.
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j GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation I
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IR 89-80 contains five NRC Outstanding Items (OIs).
We understand that the-resolution of these items will be examined in a follow-up inspection by the NRC on completion of any action that may be required.
Each of the five OIs are addressed in attachment 1 Sincerely, D. H 'i 1 Vice President and Director, TMI-1 i
HDH/MRK cc: J. Stolz R. Hernan F. Young W. Russell l
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C311-89-2084 LPage 1 of.5
-GPUN Response to IR 89-80 Outstanding Items (OIs)
OI 89-80-01 Appendix B of'the.IR, " Human Factors Comments".contains a list of human factors comments, observations and suggestions for EOP.
improvements made.by the NRC.
GPUN agreed during the inspection to' evaluate each comment and take appropriate action.
GPUN Response to OI 89-80-01:
GPUN will evaluate each comment and take appropriate action.
Certain procedure changes' recommended by the NRC inspection team.have already.been. incorporated and steps have.been initiated to disposition all of the comments within approximately three months.
The balance of any changes tx) the EOPs will be made.as part of the biennial review process.
This is to ensure the quality of the changes and to-minimize the impact on other safety related activities.
This schedule will result in the completion by December 31, 1989.of all actions that are found to be:
appropriate regarding changes to the Abnormal Transient Procedures (ATPs).
Changes to any of the other EOPs will be completed no later than October, 1991 in accordance with the biennial review schedule.
OI 89-80-02 Appendix C of the IR, " Differences between PSG's and ATP's"'
contains a list of comments and observations on deviations between the plant specific technical guidelines (PSG) contained in TDR-517 and the existing revisions of the Abnormal Transient Procedures (ATPs).
The bases for these deviations had not been documented.
GPUN agreed to evaluate each of the NRC's comments and take appropriate action.
GPUN Response to OI 89-80-02:
GPUN will evaluate each comment and complete the action as appropriate by December 31, 1989.
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C311-89-2084 l-Page 2 of 5 l
OI 89-80-03 The NRd found GPUN's administrative controls (Administrative Procedures - 1001D and 1001A) over the preparation, review and I
approval of the EOPs are adequate except for the fact that the Quality Assurance (QA) organization is not actively involved in the formal procedure review process.
With the exception of the last audit, no in-depth reviews of the procedures had been performed.
The NRC found this to be contrary to the intent'of NUREG-0899, paragraph 4.4 which states as follows:
"4.4 Quality Assurance As a primary basis of plant. Emergency Operating Procedures, plant-specific technical guidelines should be subject to examination under the plant's overall Quality Assurance (QA) Program (see Regulatory Guide 1.33).
Licensees and applicants are responsible for ensuring that its technical
. guidelines are accurate and up-to-date.
- Thus, review and control of the technical guidelines should be included in the established QA program."
GPUN Response to OI 89-80-03:
GPUN disagrees with the item.
The NRC approved GPUN QA Plan provides for the selective and graded application of QA program controls for items and activities within the scope of the QA program.
EOPs were and continue to be subject to scrutity by various assurance activities as defined by our QA progran.
Assurance of quality is not exclusive]y the provinc.e of QA department personnel.
The focus of EOP review activities by QA Department personnel has primarily been through monitoring of plant personnel, audits of Operations Department activities, observations during simulator exercises, and use of the EOPs during the limited number of actual plant transients that have occurred.
We disagree with the comment in the inspection report that all of the QA organization's involvement was after the fact.
It should also be noted that QA was actively involved in the initial meetings held in the early 1980's.
The inspectors expressed their belief during the inspection that GPUN's administrative control over the EOPs should require an in-line review function by the QA organization.
l NUREG-0899 contains no such explicit requirement.
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' Attachment 1 C311-89-2084 Page 3 of 5 GPUN Response to OI 89-80-03 (Contd.):
GPUN does not believe that in-line procedure reviews by QA personnel is required to meet the intent of the NUREG.
Nor would it be appropriate to rely upon such reviews to ensure quality.
The fact that QA department personnel are not included in the formal review process through in-line reviews of EOPs does not correlate with lesser quality documents being produced.
The quality of the documents produced at GPUN is the responsibility of the procedure preparer /" owner" and others who review and approve the document for use.
The procedure 1
review process relies heavily on the input of various GPUN functional organizations, each of which provides a level of assurance of quality through oversight and concurrence with the input of the others.
We feel that the adequacy of the procedures produced by this process further supports previous GPUN's decision that the QA department should focus on the implementation of the program rather than the administrative development of the procedures.
The inspection report acknowledges that a detailed audit of EOPs was conducted by the QA organization.
It does not note that the audit by GPUN personnel identified many of the same types of comments listed in Appendix B.
The QA comments were.
noted for evaluation and incorporation during the next biennial review of the EOPs.
It is our belief that GPUN's performance-based approach clearly meets NUREG-0899 and Regulatory Guide 1.33 requirements.
We find that this approach has been effective in focusing on those areas having the greatest impact on nuclear safety.
The fact that the inspection team's detailed review did not identify substantive issues is an indication that the QA overview of TMI-l EOPs is effective.
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- OI 89-80-04' The inspection report states that through use of the checklist for biennial review of the EOPs, GPUN should have identified many of the weaknesses' identified by the inspection, team.
The.
' checklist requires a. desk ~ top review for technical adequacy and a plant walk-through to ensure. useability.
The report finding states that GPUN should strengthen the biennial review process.
GPUN Response to OI 89-80-04:
It.should be noted:that the list of comments.in Appendix B are stated to'be " human factors comments, observations, and suggestions for EOP improvements".
GPUN does not believe the list of comments-represents significant.wcaknesses.
- However, we'are receptive to the NRC's suggestions that will result in' procedural enhancement or improvements in the biennial review process.
As discussed in response to OI 89-80-01, GPUN is reviewing the list of comments included =as Appendix B'to the report. In addition to determining the validity and'dispositioning each of the comments, we will be evaluating the comments to determine if additional guidance needs to be provided to the procedure owners in conducting their biennial reviews of the EOPs.
Certain improvements have been identified in order to better reflect management's standards for well-written procedures.
This has resulted in changes that have been made to Administrative Procedure 1001K, " Biennial Procedure Review,"
and Administrative Procedure 1001E, " Writer's Guide for Abnormal Transient Procedures."
If it is concluded that there are additional areas regarding the preparation and review of these procedures where we feel that improvement is I
needed, appropriate guidance will be provided.
This review (see response to OI-90-80-01), including any additional actions that may be appropriate, will be completed by L
December 31, 1989.
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C311-89-2084 Page 5 of 5 OI 89-80-05 This finding states that there does not appear to be any formal process to ensure that the technical guidance document will be maintained current.
During the inspection GPUN committed to develop a formal program for the maintenance of TDR-517 consistent with safety significant changes.
GPUN Response to OI 89-80-05:
GPUN will implement a process to ensure that the technical guidance document (TDR-517 or an equivalent GPUN document),
is maintained current with respect to safety significant changes in the ATPs.
Implementation of the process will be completed by December 31, 1989.
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