ML20209C038

Provides Summary of Procedure Problems Associated W/Rcs Draindown/Emergency Corrective Actions.Procedures of Prime Importance in Assuring & Maintaining Safe Conditions within Reactor Core & Reactor Bldg

ML20209C038
Person / Time
Site:	Three Mile Island
Issue date:	02/24/1983
From:	Grant P Office of Nuclear Reactor Regulation
To:	Barrett L Office of Nuclear Reactor Regulation
Shared Package
ML20209C045	List: ML20209C038 ML20210A288 ML20210A424 ML20210A460 ML20210A532 ML20210A572 ML20210A594 ML20210A616 ML20210A682 ML20210A704
References
NUDOCS 8303160605
Download: ML20209C038 (8)

Text

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' February 24, 1983 ustw yedM'

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ATTACHMENT 7 Lake H. Barrett, Deputy Program Director MEMORANDUM FOR:

TMI Program.0ffice .

FROM:

Philip J. Grant, Nuclear Engineer

" TMI Program Office

SUBJECT:

PROCEDURE PROBLEMS ASSOCIATED WITH RCS DRAINDOW CORRECTIVE ACTIONS- .

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As per your request, I have sumarized below some of the major deficie identified on the subject procedures.

poor quality, inadequate PORC review, inconsistencies wi ,

. procedures and safety precautions. -

In regard to safety significance, next to head lift and fuel removal, these procedures are of prime importance in assuring and maintaining safe conditions within the reactor core and reactor building, and provide guidance and

• direction to the operators in taking the necessary corrective actions.

Specific Comments p ,

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1. Two procedu es (2104-10.1 and 10.2), approved by PORC would have alloweti.

secondary system pressure to exceed RCS pressure. This would violate 320 M6' limits and conditions' established in, existing procedures, as well as exceed the boundaries of the SER's for both " Quicklook" and the planned 4

underhead characterization task.

2. Procedure (2104-10.2), would have allowed RCS draindown to exgged limit This (328 ELV) established by GPU Licensing letter to NRC dated 2/rW 83'.

action would have also exceeded condition's' previously bounded by the above

• mentioned SER's.

3. Procedure (2202-5.5), on " Loss of RCS Level Indication", did not incorporate the new RCS standpipe level indicator, nor properly correct for pressure compensation on existing level indicators and the procedure may have mislead the operator to make an improper corrective action.

Valve lineup procedure (2104-10.1), to insure operability of OTSG 1evel l J indicator (HeiseGage),wasinadequateandrequiredcorrection.

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February 24, 1983 1.ake H. Barrett - _ _ _ . . . . -- - .- . _.__ - -

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!d?.{Ck.- ('olation 6 /2-- of SPC system did not include SPC-V-73 which bypasses isolation

5. Is

) valve SPC-V-71. This could have allowed inadvertent injection of waterj u

into RCS and possible overflow of RCS out the CRDM openings

6. Inconsistencies existed between RCS water level eleva' tion and meas ,

on water level indicators (inches).

7.- Isolation of demin water sources did not address the RCS (Reactor Coo Feed System), and the possible boron dilution event from cperator error.

8. The surveillange testing section of systems (e.g., DHR, MDHS, CFS, ICCN, etc.),wasnot consistentwithGP$apparentplansforfuturetesting.

These com.T.ents, in addition to less significant items, have beenCurrently fcmardedweto GPU and corrections have been made to the existing procedures.

are awaiting four procedures before RCS draindown can be implemented.

M Philip J. Grant Nuclear Engineer -

TMI Program Office cc: A. Fasano J. Wiebe ,

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pg ATTACHMENT 8 I p1* GPU Nuclear Corporation

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i. *souin'8 Middletown. Pennsylvania 17057 717 944 7621 TELEX 84 2386 Writer"s Direct Dial Number:

March 4, 1983 Mr. L. P. King 704 Linden Avenue Hershey, Pennsylvania 17033

Subject:

Concerns of Mr. L. P. ' King Regarding TMI-2 Activities Attached hereto is a memorandum setting forth what I understand to be the concerns you have about TMI-2 activities. Please let me '

know if you have anything to add to this memorandum. The Company will be investigating and evaluating the potential issues you have raised.

Very truly yours l  %

R. C. Arnold President Attachment slm GPU Nuclear Corporation is a subsidiary of tne General Public Utilities Corporation

Inter-@ffico Momerandum 5

Date Ibrch 4, 1983 Concerns of Mr. L. P. King Ir p1NuoDear Subject Regarding TMI-2 Activities Location To L. P. King The purpose of this memorandum is to set forth concisely and fully the con-cerns that you have with regard to TMI-2 activities.

This includes those items identified in the discussion held at your request with Mr. Clark on February 25, 1983. I have reviewed with Mr. Clark his notes from that discussion, and he has reviewed the draft of this memoran-dum to help ensure that your concerns are understood and properly recorded l

here.

While we are particularly interested in any concerns you have regarding safety, we are also interested in those concerns you have regarding effec- l tive and efficient conduct of all activities at TMI-2.

I recognize that our discussion of these issues is potentially affected by I I

our serious concerns which we have identified to you about your involvement

in, or knowledge of, the hiring of GPU System employees by Quiltech, a com-pany of which we understand you are president. However, those issues will j

l be addressed separately. 1 In the area of safety concerns, it is my understanding that you have the following general concerns:

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1. The emphasis on meeting schedules tends to prevent and dis-courage adequate consideration of potential safety issues.

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2. The willingness of sore members of TMI-2 management (in-cluding Messrs. Kanga, Barton, and Thiesing) to fully con- -

sider potential safety issues is inadequate and tends to dis-courage issues from being raised.

3. Based upon your experience, you concluded that Thiesing can-not be trusted to tell the truth and thus one cannot rely upon his technical work, judgments, and statements relative to safety issues.

AOCC0648

L. P. King

, - Page 2 March 4,1983' 4

4. There is insufficient involvement by Messrs. Arnold and/or Clark for them to be aware of the fact that sa_fety issues ,

3 are not being considered adequately in TMI-2 activities.

5. Site Operations Department does not always-have sufficient time, and in some instances sufficient technical information, to assure they can adequately fulfill their role relative to safety implications of cleanup activities. For example, the Safety Evaluation Report (SER) may not be available ~on a timely basis for careful checking by. Site Operations of the related

. procedures against the final SER.

6. The practice of providing " draft" procedures to the NRC is being used to pressure Site Operations to sign off on pro-cedures without adequate consideration of potential safecy issues.

7. Bechtel's initial technical work products are sometimes in-adequate.

8. Preparation of engineering changes and procedures which con-trol TMI-2 activities is sometimes not in accordance with appropriate requirements; e.g., sometimes systems, equipment, engineering changes, or procedures are inappropriately classi- '-

fied as not "important to safety" and thus related activities are not subjected to the appropriate safety and QA/QC reviews (this problem is partly the result of the need to update the Quality Classification List which helps to control and deter-mine those decisions).

9. Minutes of some meetings do not document potential safety issues that are raised during the meetings.

10. There is insufficient involvement by Q'A/QC, Site Operations, and ,

the Safety Review Group in work done by Mr. Thiesing's department and thus inadequate assurance of safety; e.g., the polar crane repairs and modifications will not get reviewed by Site Opera-l tions and QA until after the crane has been used to make sig-i nificant lifts above the reactor.

While it is my understanding that you do not know of any activity that has been carried out that was unsafe, there are specific examples (in addition to those cited above) as to how those previously described circumstances have created the potential for work to be done without adequate require-ments for safety. You have documented a number of these over the last several months by means of memoranda and copies of these memoranda are

! contained in Site Operations files. Some of the specific ones that you can recall are:

)

L. P. King .

S Page 3 '

March 4,1983

l. NRC contacted you about improper safety classification of some equipment or procedures and you told them this 'was a .

frequent problem. NRC (Barrett) said NRC would follow up and you believe the classification was changed. Ron Warren has documented concerns about the issue in several memoranda.

2. Minutes of Head Lift Status Meetings do not reflect issues raised during th'e meetings.

3. You and Mr. Gischel (who is very knowledgeable about cranes) were specifically instructed not to get involved in the prepara-tion for restoration and testing of the polar crane because it was not the responsibility of Site Operations.

4. Mr. Barton was critical of your memorandum which documented that you and Mr. Gischel had been told not to get involved in the preparations for the polar crane restoration and testing.

5. The Bechtel-prepared draft SER for the polar crane restorati.on and testing was considered by the.NRC to be of very poor quality, and they requested a thorough review of the SER by GPUN.

6. You concluded the subsequent revised SER for the polar crane was

, also technically inadequate. ,,

7. Messrs. Kanga and Barton were unwilling to address adequately your concerns about the polar crane. However, you agree that if the load drop accident calculatio'sn are valid and a careful re-view by QA/QC is accomplished properly (and any items _ identified t are resolved) then the polar crane restoration and testing pro-gram will be technically adequate. Nevertheless, you advocate a review of whether ALARA and schedule considerations in fact outweigh the benefits of a more extensive testing and inspection sequence for requalification of the polar crane.

8. Site Operations (specifically Mr. Gischel and you)' had inadequate opportunity to review.the basis for the polar crane restoration -

and test program before being asked to " sign off" on the polar l J

crane SER.

9. You and QA (Ballard) had to force the issue to get Freemerman to agree that administrative procedures AP 1043 and AP 1047 applied to polar crane testing.

10. You are not sure that all repairs to the polar crane involved re- l placement "in kind." If that is not the case, the work should  !

have been controlled as a modification to the crane.

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- March 4,1983 3 11. You are not sure that the load drop analysis described in the .

polar crane SER was in fact actually done although Bechtel claims it was done.

12. You are not sure that the GORB minutes, Recommendations, and Action Items reflect the issues ~ discussed by them during their

- review of the polar crane program.

13. The draft SER for the neasurement of radiological conditions "

under the reactor head was not finalized in time to support

' the schedule so a decision was made to proceed based upon the SER for the " Quick Look." You question.whether the procedures prepared based on the draft SER was consistent with the " Quick Look" SER. Only the Safety Review Group (Kunder) reviewed the draft procedures'against the " Quick Look" SER--the Site Opera-tions staff did not. The SRG approved;the procedures " subject to comment" which is not the normal practice. The draft pro- ,

cedures were-furnished to the NRC and they commented negatively on the preparation process for the procedures. .

With regard to the effectiveness of the management of the TMI-2 program, you have the following general concerns: .

1. Bechtel personnel are inefficient and in many instances incompe- '_

. tent.

1 i 2. Activities such as engineering, procurement, and procedure prep-aration are not being scheduled on an integrated basis along with the field work. This is causing inefficiencies as well as having i

the implications to safety discussed above.

3. You have tried to have your concerns addressed by Messrs. Barton and Kanga without success. In' addition, they are either failing j- to identify your concerns to me or I am failing to address them and " hiding behind" Mr. Kanga.

Some specific examples you consider to be illustrative of the deficiencies of the management are:

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1. Bechtel failed to complete on time the ECM for installation of equipment for measuring water level during the d. raining of the Steam Generators. Therefore, you had to provide an alternative means and get NRC approval for the associated procedures.

2. GPUN established a schedule of mid-1983 for obtaining gas and liquid samples for the purification system demineralizer and then advanced the schedule to an earlier date because of pres-sure from the NRC. This caused you to have~to pursue the effort on a " crash" basis instead of at a more deliberate pace.

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-L. P. King i Page 5 March 4,1983 -

3. You believe' Site Operations has accomplished decontamination in the Auxiliary Building at a much lower cost then would have been the result if Bechtel had managed that work as originally planned.

4. You tried to get these concerns addressed by Barton and his management at the time of your annual performance review and.

were. unsuccessful.

On a related subject, you believe that Bechtel (perhaps with directions from GPUN) contacted Quiltech, the company of which you are president, for the pur-pose of either:

1. Offering work to your firm in return for your being quiet ,

about your concerns; or

2. Trying to compromise you with GPUN (perhaps relative to the ,

GPU Conflict of Interest Policy).

I also understand that you believe you were suspended on February 24, 1983 (while the Company investigated your involvement with Quiltech and its employment.of GPUN personnel) in retaliation for your having stated your concerns about THI-2 activities.

' To the best of my knowledge this memorandum describes all of your significant-general concerns as to safety and effectiveness of TMI-2 activities. Please let me know if there are any other concerns which you believe need to be.ad-dressed and resolved.  ;

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Q R. C. nold slm .

cc: P. R. Clark H. M. Dieckamp B. K. Kanga y , e ~- + - - - -