IR 05000219/1982012
| ML20054G678 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 05/25/1982 |
| From: | John Thomas, Lester Tripp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20054G674 | List: |
| References | |
| 50-219-82-12, NUDOCS 8206220192 | |
| Download: ML20054G678 (57) | |
Text
ENCLOSURE 1
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMt.NT Region I Report No.
50-219/82-12 Docket No.
50-219 License No.
DPR-16 Priority Category
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Licensee:
GPU Nuclear Corporation P.O. Box 388 Forked River, New Jersey Facility Name: Oyster Creek Nuclear Generating Station Meeting at:
Forked River, New Jersey Meeting conducted: April 16,1982 NRC Personnel:
ht4 es Pu D. Af Jhom@ Resident / Inspector diite signed f
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Approved by:
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L. E;Aripp,JChief, Reactor Projects date signed Section 2A Meeting Sumary:
Meeting on April 16, 1982 (Meeting Report No. 50-219/82-12)
Scope: Special management meeting to discuss the results of the NRC Region I assessment of the licensee's performance from November 1,1980 to October 31, 1981, as part of the NRC's Systematic Assessment of Licensee Perfomance (SALP)
program. Areas addressed included: Plant Operations, Radiological Controls, Maintenance, Surveillance, Fire Protection, Emergency Preparedness, Security and Safeguards, Refueling, and Licensing activities.
Results: A sumary of the NRC licensee performance assessment was presented. No new enforcement actions were identified.
8206220192 820616 PDR ADOCK 05000219
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i DETAILS 1.
Licensee Attendees M. Budaj, Manager, Special Projects J. Carroll, Jr., Director, Station Operations P. Clark, Executive Vice President R. Fenton. Supervisor, Emergency Preparedness K. Ficketsrfn, Plant Engineering Director P. Fiedler, Vice President and Director, Oyster Creek J. Frew, Plant Maintenance D. Gaines, Manager, Plant Administration W. Garvey, Manager, Plant Administration D. Grace, Manager, Oyster Creek Engineering Projects D. Klucsik, Communications
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J. Knubel, BWR Licensing Manager M. Laggart, Licensing Supervisor J. Maloney, Manager, Plant Maintenance R. Markowski, Site Audit Manager J. Riggar, Security Supervisor J. Sullivan, Jr., Plant Operations Director C. Tracy, Manager, Quality Assurance, Mod / Ops D. Turner, Manager, Radiological Controls 2.
NRC Attendees J. Allan, Deputy Regional Adninistrator, Region I C. Cowgill, Senior Resident Inspector, Peach Bottom R. Keimig, Chief, Reactor Projects Branch 2, Division of Project and Resident Programs, Region I J. Lombardo, Licensing Project Manager, NRR R. Starostecki, Director, Division of Project and Resident Programs, (DPRP), Region I J. Thomas, Resident Inspector, Oyster Creek L. Tripp, Chief, Reactor Projects Section 2A, DPRP 3.
Discussion A brief summary of the Systematic Assessment of Licensee Performance (SALP)
program was presented to explain the basis and purpose of the program.
The NRC Region I assessment was discussed, including the assessment period, evaluation topics and methods, and assessment results. The licensee dis-cussed actions taken and planned to continue performance improvements and address weaknesses.
The SALP assessment report and your May 6,1982 letter which we requested in our April 7,1982 letter in response to that report is also enclosed with this transmittal.
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ENCLOSURE 2 U. S. NUCLEAR REGULATORY COMMISSION
REGION I
I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE GPU NUCLEAR CORPORATION OYSTER CREEK NUCLEAR GENERATING STATION March 29, 1982
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i SUMMARY (11/1/80 - 10/31/81)
OYSTER CREEK NUCLEAR GENERATING STATION HOURS
% OF TIME 1.
Plant Operations 1053
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Radiological Controls 223
3.
Maintenance 128
4.
Surveillance 201
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Fire Protection
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1 7.
Security and Safeguards 202
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Refueling
2 9.
Licensing Activitives No Data Available 10. Other 104*
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- Total 2062 100%
104 hours0.0012 days <br />0.0289 hours <br />1.719577e-4 weeks <br />3.9572e-5 months <br /> of region based investigation in response to a radioactively
contaminated spent fuel shipping cask.
Allocations of inspection hours vs. Functional Areas are approximations
based on inspection report data.
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TABLE 4 INSPECTION REPORT ACTIVITIES OYSTER CREEK NUCLEAR GENERATING STATION REPORT INSPECTOR AREAS INSPECTED 80-33 Resident Routine 80-34 Specialist Post-Refueling Testing 80-35 Resident Routine 80-36 Specialist Physical Security 80-37 Specialist Transportation 80-38 Investigator Shipping Cask Contamination 81-01 Resident Routine 81-02
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Management Meeting 81-03 Resident Routine 81-04 Specialist Radiation Protection 81-05 Specialist Surveillance, Calibration 81-06 Resident Routine 81-07 Specialist In-Service Inspection 81-08 Specialist In-Service Testing, Quality Assurance, Design Changes, Maintenance 81-09 Specialist Radiation Protection 81-10 Resident Routine 81-11 Resident Routine 81-12 Resident Routine 81-13 Specialist Physical Security
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Table 4 (Con'td)
REPORT INSPECTOR AREAS INSPECTE0 81-14 Resident Routine 81-15 Specialist Radiation frotection 81-16 Resident Routine 81-17 Resident Shutdown Cooling Heat Exchanger Failure 81-18 Resident Routine 81-19 Resident Routine 81-20 Specialist Independent Measurements
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TABLE 5 VIOLATIONS (11/1/80 - 10/31/81)
OYSTER CREEK NUCLEAR GENERATING STATION A.
Number and Severity Level of Violations 1.
Severity Level Severity Level I
_3 Total
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Violations Vs. Functional Area Severity Levels FUNCTIONAL AREAS I
II III IV V
VI 1.
Plant Operations
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2 2.
Radiological Controls
2
3.
Maintenance
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Surveillance
3
5.
Fire Protection 6.
Security & Safeguards
1 8.
Refueling 9.
Licensing Activities Totals
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13
Total Violation = 35
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Table 5 (Con't)
i TABLE 5 ENFORCEMENT DATA
OYSTER CREEK NUCLEAR GENERATING STATION
November 1, 1980 - October 31, 1981 Inspection Inspection Number Date Subject Req.
Sev. Area
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80-36 12/13-19/80 Failure to secure vital area barriers PSP IV
80-36 12/13-19/80 Use of improper I.D. badge PSP IV
I 80-36 12/13-19/80 Failure to conduct protected area key PSP IV
audit and failure to change safe i
combinations
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80-36 12/13-19/80 Explosives detector performance tests PSP IV
were not conducted f
80-36 12/13-19/80 Inadequate lighting at locations in PSP IV
the protected area 80-36 12/13-19/80 Failure to retain certain records as PSP IV
required
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80-37 12/30/80 LSA radioactive material was delivered 49CFR III
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to a carrier for transport in a package 173
that was not a strong, tight package 80-37 12/30/80 LSA radioactive material was delivered 49CFR III
to a carrier for transport without 173 properly describing the physical form of the material in the shipping papers 81-01 1/5-31/81 Annunciator and Alarm procedures was TS V
not followed i
81-03 2/2-28/81 Failure to follow dosimetry issue TS V
procedures
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Inspection Inspection Number Date Subject Req.
Sev. Area 81-04 3/2-681 Administrative Control requirements for TS V
procedure changes were not followed 81-05 3/9-13/81 Test gauges used for safety related AppB V
calibrations are not of acceptable accuracy or readability for the calibrations being performed 81-05 3/9-13/81 Calibrations are performed on safety TS V
related instruments without using approved procedures, and diesel generator KW and KVAR meters and fire pump RPM meters are not being calibrated 81-05 3/9-13/81 Failure to test valves as required by AppB V
the inservice test program 81-05 3/9-13/81 PORC meeting minutes are not being TS V
distributed to the ISRG and GORB as required by T.S.6.5.4.1 81-05 3/9-13/81 Ann.ual reviews of operating procedures TS VI
were not performed 81-05 3/9-13/81 Calibration data was omitted from TS VI
instrument history cards and had not received supervisory review 81-05 3/9-13/81 The core spray pump test procedure was TS VI
not revised to reflect that the fill pumps no longer operate automatically 81-06 3/1-31/81 Safety related material was purchased AppB V
on requisition 61619 without 0QA review 81-08 3/30-4/3/81 Pump operability tests were not performed AppB IV
in accordance with Section XI of the ASME B&PV Code 81-08 3/30-4/3/81 Handling, Storage, and preservation AppB V
of materials and equipment to prevent damage or deterioration, and the cleanliness of the Level B storage area were not in conformance with ANSI N45.2.2
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Table 5 (Con't)
Inspection Inspection Number Date Subject Req.
Sev. Area 81-10 4/1-30/81 One reactor building to suppression TS II
chamber vacuum breaker in each line was rendered inoperable by the placement of contractor erected scaffold 81-10 4/1-30/81 Corrective action has been ineffective AppB IV
in correcting conditions adverse to quality which present the potential for the release of radioactive material from the condensate transfer pump building
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81-11 5/1-30/81 Several electrical jumpers were found TS V
improperly installed or disconnected 81-12 6/1-30/81 The required daily surveillance was TS
4 not performed on emergency service water pumps when the redundant pumps were inoperable 81-12 6/1-3L/01 A high radiation area was not locked TS IV
or guarded to prevent unauthorized entry 81-13 6/8-12/81 A vehicle in the protected area was PSP V
left unlocked, unattended with the keys in the ignition 81-14 7/1-30/81 Secondary containment integrity was not
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maintained as required when valve V-28-22 was inoperable and not secured in the closed position 81-14 7/1-30/81 Instrument channel checks of the accident TS IV
monitoring instruments were not performed monthly from May 8, 1981 to July 13, 1981 81-14 7/1-30/81 The southeast containment spray pump TS IV
compartment water tight door was left open in violation of technical specification
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Table 5 (Con't)
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Enspection Inspection
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Number Date Subject Reg.
Sev. Area 81-16 8/4-9/14/81 Personnel entered a high radiation TS IV
area without proper radiation dose rate monitoring equipment 81-16 8/4-9/14/81 Failure to follow procedures during TS V
performance of surveillance test 81-17 8/27-10/19/81 Failure to report an unplanned, 10CFR IV
uncontrolled radioactive liquid release 50.72 81-18 9/15-10/5/81 Failure to follow procedures for conduct TS V
of shift turnover 81-18 9/15-10/5/81 Failure to implement test procedures with AppB IV
adequate acceptance criteria for the station batteries i
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- ENCLOSURE 3
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OPU Nuclear NUC Mr 100 Interpace Parkway Parsippany, New Jersey 07054 201 263-6500 TELEX 136-482 Wnter's Direct Dial Number:
May 6, 1982 Mr. Richard Starostecki, Director Division of Project and Resident Programs U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Starostecki:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Systematic Assessment of Licensee Performance (SALP)
Your letter of April 7, 1982 provided, for our review and response, a draft Systematic Assessment of Licensee Performance (SALP) report concerning activities conducted at the Oyster Creek Nuclear Generating Station for the period November 1, 1980 through October 31, 1981. Attachment I to this letter provides our responses to the maintenance and surveillance areas which were classified as areas of weakness.
In addition to our specific responses concerning those two areas, we are taking this opportunity to provide comments on the other areas which were evaluated. The additional comments, also contained in Attachment I, are provided to help meet the SALP objective of furthering NRC's understanding in how the licensee management directs, guides, and provides resources for assuring plant safety.
Very truly yours,
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Philip R/ Clark Executive Vice President GPU Nuclear Corporation cc:
Mr. Ronald C. llaynes, Administrator Region L U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731 GPU Nuclear is a part of the General Public Utihties System
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ATTACHMENT I Subject:
Responses and Comments to the NRC Systematic Assessment of Licensee Performance (SALP)
Evaluation Period:
November 1,1980 Through October 31, 1981 Summary of NRC Evaluation:
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FUNCTIONAL AREAS OYSTER CREEK NUCLEAR GENERATING STATION CATEGORY CATEGORY CATEGORY
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1.
Plant Operations X
2.
Radiological Controls X
3.
Ma in tenance X
4.
Surveillance (Including Inservice and Preoperational Testing)
X-5.
Fire Protection and Housekeeping X
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~X 7.
Security & Safeguards X
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Refueling X
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Licensing Activities X
f Category Definitions:
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Reduced NRC attention may be appropriate. Licensee management I
attention and involvement are aggressive and oriented toward nuclear safety; I
licensee resources are ample and effectively used such that a high level of I
performance with respect to operational safety or construction is being l
achieved.
Category 2:
NRC attention should be maintained at normal levels. Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably ef fective such that satisfactory performance with respect to operational safety or construction is
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being achieved.
Category 3:
Both NRC and licensee attention should be increased. Licensee j
management attention or involvement is acceptable and considers nuclear safety, i
but weaknesses are evident; licensee resources appeared strained or not l
ef fectively used such that minimally satisf actory performance with respect to l
operational safety and construction is being achieved.
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Page 2
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Plant Operations - NRC Evaluation During the previous assessment period, (August 1, 1979 - July 31, 1980),
several violations were identified involving procedural inadequacies, inadequate mechanisms for issuance of management instructions, and failure to follow procedures. Of particular importance was an incident involving failure to remove control rod interlock bypass jumpers prior to completion of control cell fuel reload.
Programmatic weaknesses were identified in'
the area of adherence to management controls procedures at the lower management and supervisory levels, and in the area of meeting commitments to the NRC..An improving trend was noted as licensee management responded in a positive manner to address the identified weaknesses.
This area was under continuing review by the resident inspector for the current (November 1, 1980 - October 31, 1981) assessment period. Twelve operations related violations were identified. Failure to follow procedures resulted in four Severity Level V violations.
Inadequacies in the area of administrative controls resulted in one Severity Level V violation when PORC meeting reports were not properly distributed, and two Severity Level VI violations involving failure to properly review or revise operating and surveillance procedures. Two Severity Level IV
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violations were identified involving failure to recognize a containment integrity violation when an isolation valve failed during testing, and recurrent violations of technical specifications when containment spray compartment water tight doors were left open. Failure to report an unplanned radioactive release and inadequate corrective action on recurrent spills of radioactive liquid resulted in twa Severity Level IV violations. One Severity Level II violation involving vacuum breaker blockage was indicative of inadequate controls over activities affecting plant operations, and sometimes inadequate tours of the plant by operations personnel. Thirty-two licensee event reports were related to
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the operations area.
Reports were generally timely and accurately identified the causes and corrective actions needed.
Improvements have been noted in management involvement in this area. The i
f licensee has implemented a Nuclear Assurance Department Operations Support i
Program. The program involves the assignment of an Assistant to the Plant l
Operations Director and Shif t Assistants who are tasked with reviewing I
plant operations and making recommendations for improvement in the areas of procedural adequacy, procedural adherence, and control of activities that have an impact on operations. Also, corporate management has issued policy statements stressing verbatim compliance with operating procedures
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and has begun vigorously enforcing the policy.
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This program has resulted in many improved procedures, improved procedural i
adherence, improved operation awareness and understanding of plant activities, improved followup of operations identified maintenance
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concerns, and improved operator morale. The program has relieved some management and supervisory personnel of administrative burdens, allowing more timely and thorough reviews of activities.
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Page 3 The development of a " programs and controls" group has improved the i
scheduling and prioritization of work activities and the coordination between maintenance and operations.
Some problems still exist with operator knowledge of regulatory requirements. These problems are evidenced by the following:
(1) Failure to recognize malfunction of a TIP in-shield limit switch as a degradation of containment intgrity.
(2) Failure to recognize failure of a reactor building ventilation isolation valve as a degradation of containment integrity.
(3)
Interpretation of exceeding a peaking factor limit during a power
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transient as a " Safety Limit Violation".
Licensee corrective and preventive actions have been generally acceptable and indicative of a responsiveness to NRC concerns.
i Conclusion
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GPU Nuclear Corporation Comments:
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The third paragraph in the above evaluation references a Nuclear Assurance Department Operations Support Program. This is a misnomer. The comment
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is made in order to avoid confusion between activities conducted by our Nuclear Assurance division and this program.
The program consisted of temporarily assigning experienced personnel, from other divisions within GPUNC, including the Nuclear Assurance Division, to aid in the site specific activities of the Operations, Maintenance and Plant Engineering departments of the Oyster Creek Division. These specific assignments were made on a temporary basis to fill vacant positions. At the present time, the temporarily assigned personnel have returned to their respective divisions. Continuity of the program will be based on an overall evaluation of the program and permanent personnel have been placed in many positions.
With regard to the statement in the last paragraph of the evaluation that some problems still exist with operator knowledge of regulatory requirements, a comprehensive formal refresher training program has been
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developed for Operations Shift Supervisors in the area of Technical
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Specification and regulatory requirements.
The results achieved by a program of this nature would not be observable in the short term, but are expected to result in improvements in this area.
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Radiological Controls - NRC Evaluation
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.The previous assessment period identified several areas of major concern.
Programmatic problems included inadequate staffing, use of personnel not meeting ANSI N18.1-1971 standards, procedures inconsistent with Technical Specifications, and poor control in the area of transportation of radioactive waste. Nineteen violations were identified and one civil penalty was assessed for inadequate radiation work permit procedures. An improving trend was noted in the latter part of the assessment period when action was taken to upgrade the radiation protection training program, increase the s'ize and quality of the radiation protection staf f, and implement organizational changes to put direct management attention in the areas of radwaste operations and shipping.
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During the current assessment period, four inspections were performed by region based inspectors in the area of radiological controls. One included a review of the radwaste management program and two included review of effluent monitoring and control.
In addition, one regional office evaluation of a State of Nevada burial site inspection, and one investigation of NAC-1E shipping cask event were conducted.
Selected activities in this area were under continuous review by the resident inspector. Six violations, two Severity Level III's associated with radioactive waste transportation, two Severity Level IV's associated with control of high radiation area access, and two Severity Level V's associated with dosimetry issue procedures and control of procedure changes were identified. These items were not repetitive or indicative of programmatic breakdowns. Corrective actions were timely.
Two licensee event reports identified unmonitored uncontrolled liquid releases. Four operations related event reports identified failures to
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monitor gaseous effluents due to sample system breakdowns. The events
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Management involvement in this area is evidenced by the major reoganization of the radwaste management program and generally well t
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However, lack of formal approval of Radiation Control Technician training program remains a long-standing issue. The General Employee Training Program contributes to fair adherence to procedures and minor numbers of personnel errors. The plant staffing appears to be adequate and the radiological engineering reviews show evidence of
adequate planning and technically sound approaches to problems.
Conclusion Category 2
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l Page 5 GPU Nuclear Corporation Comments:
The radiological Field Operations Training Program, referred to in the fourth paragraph, has now been submitted for NRC review and approval. As you are aware, until NRC approves this program, each member of the radiation protection organization, for which there is a comparable position described in ANSI N18.1-1971, meets or exceeds the minimum qualifications specified therein.
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Maintenance - NRC Evaluation:
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Three inspections during the previous assessment period identified no violations. Three of four maintenance related event reports involved personnel error. The assessment concluded that the licensee had a viable maintenance program with no major programmatic weaknesses.
During the current assessment period, one region based inspection and routine inspection by the resident inspector identified no violations.
In
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an effort to improve the maintenance program, the licensee has assigned a full time preventive maintenance manager and a full time corrective maintenance manager reporting to the plant maintenance manager. This has placed increased management attention on the control of maintenance activities; however, there is a lack of corporate and plant management involvement in the review and prioritization of outstanding maintenance items and an' apparent understaffing in maintenance departments. There is a large backlog of outstanding work orders and frequent instances where job orders are closed out when only tamporary repairs are completed, or where job orders considered to be of minor importance are cancelled.
l In addition to a backlog of maintenance orders, there is a large number of l
long-standing lifted leads and jumpers. These have not been closed because of incomplete maintenance modifications which did not include permanent removal of abandoned compone..to, or the need for further
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engineering review.
The preventive maintenance program is being expanded and crews dedicated specifically to preventive maintenance are being formed. This program presently involves primarily instrumentation and lubrication. Maintenance records are reviewed by a preventive maintenance engineer who is developing machinery history records, but this program has not yet been developed to the point that maintenance trend analysis can be performed.
In addition to marginal maintenance history records, the availability of current equipment data is a weakness. Controlled files of equipment data with component model and serial numbers, parts lists, and engineering drawings are not always up to date.
For example, the controlled valve list does not reflect the fact that the reactor building to suppression chamber air operated vacuum breakers were replaced with valves made by a dif ferent manufacturer in 1979.
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Page 6 The licensee's response to NRC initiatives is sometimes delayed. For example, corrective actions on a 1977 IE Circular relating to fuse coordination in Standby Liquid Control system Squib firing circuits, a 1979 IE Circular relating to defective diesel fire pump starting contractors, and a 1979 IE Circular on Limitorque valve operator locking devices were not completed until the NRC' expressed concern for lack of responsiveness.
An event during the assessment period involving blockage of torus vacuum breaker valves by contractor erected scaffolding resulted in a Severity Level II violation and assessment of a civil penalty. Another event involved an unmonitored airborne release of radioactive material from the radwaste building ventilation system. These events are indicative of inadequate control of contractor work. Af ter the assessment period, an event involving improper assesmbly and testing of a torus vacuum breaker valve was discovered. The action resulted in one torus vacuum breaker l
being inoperable for about 18 months during reactor operation. This event, which is still under review by the NRC, indicates that a I
strengthening of management control and procedural control over
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maintenance activities is necessary.
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The licensee has implemented a program of increased management involvement in maintenance activities. In addition, recent staf fing changes which have placed individuals with extensive maintenance background in upper-level management positions have resulted in an improving trend in this area.
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Increased inspection effort by the resident
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inspector.
GPU Nuclear Corporation Comments::
The evaluation period (November 1,1980 through October 31, 1981)
coincides with the reorganization of our Maintenance Department in September 1980 and as such, covers a transition period. Current activities now meet most of the goals of the reorganization and satisfactorily address many of the concerns of the above evaluation.
The following paragraphs provide examples of how the reorganization has ef fected pos'itive changes which, toward the end of the evaluation period and subsequent thereto, have become clear:
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Page 7
The second paragraph of the evaluation contains the statement "... there
is a lack of corporate and plant management involvement in the review and
prioritization of outstanding maintenance items Procedure No. 105
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" Conduct of Maintenance" ensures that management reviews and prioritizes each job order. The prioritization of job orders has been in ef fect since i
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January of 1981 and consists of assigning.one of four priorities. " Urgent 1" is the most immediate p'riority and indicates that work should be
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l started within one day. This priority includes emergency maintenance l
initiated by the Group Shif t Supervisor and other work considered likely to cause any of the following conditions within three days:
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Personnel injury 2.
Significantly increased contamination or radiation hazard
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Unplanned, uncontrolled release of radioactive material to the environment in excess of normal release rates
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Significant damage to safety-related equipment needed for safe plant shutdown
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. Violation of Technical Specifications _
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Immediate plant shutdown or load reduction
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The remaining three categories involve problems of a lesser severity and guidance is given in the procedure for assigning priorities.
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The second paragraph also refers to "... an apparent understaffing in
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maintenance departments
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i to worker ratio. Currently, our average ratio is one supervisor per ten
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to twelve workers. The key maintenance positions are now filled and implementation of the desired program is being ef fected. We believe that our present emphasis on more effective use of supervision, emphasizing supervisor presence on the job site and better planning, in addition to the improved supervisor to worker ratio, will help effect the desired improvements.
The last sentence in the second paragraph states "There is,a..large backlog
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of outstanding work orders and frequent instances where job orders are closed out when only temporary repairs are completed, or where job orders
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considered to be of minor importance are cancelled." There are a large number of outstanding work orders, many as a result of our increased efforts to identify what work needs to be accomplished. However, as identified above, all job orders are prioritized according to specified criteria and the majority of outstanding job orders are in the minor category.
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Page 8 With regard to job orders being closed out inappropriately, Procedure 105 currently requires that a job order may only be cancelled by the applicable Maintenance Supervisor after obtaining concurrence of the initiating department supervisor. The procedure also identifies when temporary repairs are effected or further modification to the existing system is required, the temporary repair job order may be closed out.
A new job order is initiated for execution when materials and/or the modification package is available.
With regard to the large number of long-standing lif ted leads and jumpers referred to in the third paragraph, we have recently completed a review of and dispositioned all lifted leads and jumpers where possible. The unresolved remaining items have been identified and are being referred to engineering for permanent resolution.
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The fourth paragraph in the evaluation discusses the preventative maintenance program. We fee,1 this area has been greatly improved, since reorganization in September 1980. The present program includes electrical, mechanical, instrumentation and lubrication activities.
Maintenance history cards are now updated whenever corrective or preventative maintenance is performed. Although past history of
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. maintenance may, in some cases, be unretrievable, current practices will ensure that future trend analysis will be achievable.
Our responsiveness to NRC initiatives is now coordinated through the Licensing Department.
Each item is assigned to the cognizant department and tracked by a formal program until completion of the assignment is effected. Outstanding items are brought to the attention of upper management and a summary report is provided to the Of fice of the President on a monthly basis. The current program should help ensure that events such as the exampics cited in the evaluation will not be of a recurrent nature.
With regard to control of contractor activities, our corrective actions, as you are aware, are described in our response to the Notice of Violation dated September 21, 1931.
The controls imposed have had a positive ef fect in that potential problems are identified and corrected prior to conducting work activities.
4.
Surveillance - NRC Evaluation During the previous assessment period, six routine unannounced inspections by region based inspectors, one Performance Appraisal Branch Inspection and routine inspection by the resident inspector identified three violations. The licensee had failed to perform surveillances on three occasions.
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During the current assessment period, two region based inspections, one regional based team inspection, and routine resident reviews identified eight violations. The violations involved failure to conduct Technical Specification and ASME Section XI testing, inaccurate calibration, calibration and testing without procedure, and inadequate. calibration data and procedural changes.
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Corrective action was agreed to in an Immediate Action Letter dated
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April 8,1981. The licensee agreed to upgrade his inservice test program to meet the requirements of ASME code Section XI by January 1,1982.
After the assessment period, region based inspectors found that the licensee had not completed all corrective action, in that a program for valve testing was not fully implemented. The licensee has since submitted a revised completion schedule to NRC:RI. The licensee stated that operational commitments and manpower shortages were the reasons for not meeting the commitments. The high number of violations and the failure to meet commitment dates without notification, indicate weakness in licensee management control in this area.
The large number of event reports resulting from instrument drift and the long standing nature of this issue indicates a need for high level management involvement in this area to achieve technically' acceptable-resolution. Violations resulting from missed surveillances, in particular a Severity Level IV violation involving failure to survey Emergency Service Water pumps following unacceptable surveillance on redundant pumps, indicate a need for more management attention in review of surveillance programs and assuring unambiguous acceptance criteria.
This need is further amplified by a violation that occurred after the assessment period. Three successive failures of an isolation condenser valve during operability testing followed by two successful operations of,
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the valve, with no followup investigation to determine the cause of the failures, was interpreted by a member of the management staff as
acceptable component performance.
Conclusion
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Category 3 Board Recommendations
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None
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GPU Nuclear Corporation Comments:
Several violations that are referenced in the above evaluation inv.olved a failure to comply with the surveillance requirements of recently approved Technical Specification changes. Our practice had been that follow-up to Technical Specification changes, such as the drafting of procedures, was
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not initiated until after NRC had approved the change. At present, the Surveillance Testing Program is administered by the Plant Engineering Department and compliance to Technical Specifications is accomplished through the maintenance of the surveillance testing schedule and implementing procedures.
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Page 10 To improve the implementation of Technical Specification changes, Plant Engineering will review all pending Technical Specification Change Requests and assure that all aspects relative to the specific changes are prepared in anticipation of approval. Once approved, the draft procedures will be reviewed again for changes, which may have occurred due to NRC review, and cycled through our internal cycle for final approval and implementation. Under this program, a change to Technical Specifications should be implemented within 30 days after issuance.
As you are aware, the common NRC practice of making Technical Specification changes " effective upon date of issuance" has been addressed by us in previous correspondence as being impractical to implement. We request that all changes to Technical Specifications become effective 30 days after receipt by the licensee unless requested otherwise.
In addition to the above planned actions, Plant Engineering has instituted training in the area of Technical Specifications. All engineering personnel will be required to attend. The classroom instruction will be presented by the BWR Licensing Manager and is scheduled to be conducted during May of 1982.
An integrated training program is being developed to educate each member of the Plant Engineering staf f with regard to general BWR knowledge.
Specific system responsibility will be assigned to individuals who will be expected to acquire knowledge comparable to operations personnel for the systems assigned to them.
This is expected to raise the overall system level knowledge with regard to plant operations to a level considerably higher than before. Training in the specific system areas is expected to begin in July of 1982.
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We feel the violations referenced in the evaluation regarding the Emergency Service Water Pumps and the Isolation Condenser Valve do not indicate a programmatic weakness in the surveillance program. The decision to declare the Emergency Service Water Pumps operable was based on previous knowledge and experience of system performance. Management's decision was based on knowledge that should have been incorporated into the procedure; however, in absence of procedure criteria, the pump should have been declared inoperable. With regard to the Isolation Condenser valve operability, the cause can be attributed to poor judgement. This event has been discussed with plant operations personnel and management direction to make such judgement conservatively from a safety standpoint has been reemphasized.
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5.
Fire Protection and Housekeeping - NRC Evaluation Three inspections by region based inspectors and one Performance Appraisal Branch inspection during the previous assessment period identified no major programmatic weaknesses. Two violations were identified involving storage of combustible material in safety related areas.
During this assessment period, general fire protection activities and housekeeping were under continuous review by the resident inspector.
No programmatic inspections were performed.
No violations in this area have been identified. Two Licensee Event Reports were submitted; one, the result of mechanical failure of a fire hydrant, the other involving personnel error when a cable penetration barrier was found in a degraded
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condition.
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Management involvement in this area is evident by the assignment of a full time fire protection engineer, recent procedural revisions to provide better control of combustible material, and improved surveillance of fire barriers.
.here were considerable problems causing delays in the installation and testing of a storage tank and pumping system to provide an alternate
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source of water to the fire protection system.
a Several recent events involving wetting and ultimate impairment of safety related electrical equipment have demonstrated inadequacies in the
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original fire protection safety evaluation. High level management attention to this problem since the end of the assessment period has resulted in an extensive survey of plant systems and a program to waterproof and protect electrical components.
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Housekeeping has improved during this assessment period as a result of more management attention.
Radiological housekeeping conditions are generally acceptable with no significant NRC inspection findings in this area.
Poor general plant cleanliness and appearance; however, continues to reflect poor plant staf f attitudes and lack of professionalism / pride.
An improving trend has been noted as a result of increased management attention.
Conclusion
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Category 2*
Board Recommendations
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none
- This rating is assigned without regard to the licensee's position on 10 CFR 50, Appendix R provisions.
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GPU Nuclear Corporation Comments:
As a result of increased management attention in the area of housekeeping, we feel there has recently been considerable improvements'in plant cleanliness and appearance. We feel the continued emphasis will elevate the pride of the entire plant staff.
6.
Emergency Preparedness - NRC. Evaluation No programmatic inspections were conducted in" this area during the
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previous assessment period.
During the current assessment period, an emergency preparedness drill was observed by the resident inspector. The drill indicated weaknesses in the licensee's ability to implement the provisions of a revised emergency plan issued about one week prior to the drill. The licensee recognized the deficiencies which were also identified by several internal audits. An intensive upgrade program, which included significant increases in emergency planning staff, further emergency plan and procedure reviews, and intensive training, was begun.
An NRC team appraisal of emergency preparedness was conducted in January 1982 after the end of the assessment period. The appraisal identified significant weaknesses requiring corrective actions. These weaknesses included:
required upgrading of emergency response facilities; improved capability for post accident sampling of stack ef fluent, reactor coolant, and containment atmosphere; emergency procedure improvement; and better
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definitions of the training program for emergency response personnel. The licensee's proposed corrective actions were discussed in a Confirmatory Action Letter dated February 18, 1982.
An NRC team observation of a major emergency preparedness exercise was
conducted in March 1982. This observation determined that the licensee
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had demonstrated the capability to implement the provisions of the emergency plan to adequately protect the public health and safety during an accident, however, areas for improvement were noted and discussed with the licensee.
The licensee failed to meet the February 1,1932 deadline for installation of a Public Notification System and was issued a Severity Level III Notice of Violation. Forty-five warning sirens were installed and tested by March 5, 1982. The final siren was installed and tested on March 11, 1981.
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Category 2
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Conclusion
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Board Recommendations None
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- This categorization has been assigned on the bases of additional
.___.__._......_._information developed.after the assessment period and without regard
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to resolution of the outstand'ing issue of the Confirmatory XEti~on Letter of February 18, 1982.
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GPU Nuclear Corporation Comments:
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The last paragraph in the above evaluation contains two minor errors concerning the installation dates of our warning sirens. As we indicated in the response to the Notice of Violation, forty-five (45) warning sirens were installed and tested by February 26, 1982.
The final stren'was installed and tested on March 5,1982.
Since the SALP evaluation, we note that NRC, by their letter of April 28, 1982, has evaluated our overall
~ ~ ~ response to this matter and advised us that they plan no further action.
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7.
Security and Safeguards - NRC Evaluation During the previous assessment period, two routine inspections by region based inspectors, routine review of selected areas by the resident inspector, and one inspection by the Performance Appraisal branch identified no violations or evidence of programmatic weaknesses. During one inspection, allegations by a former security watchman, which had been published in a local newspaper, were reviewed but could not be substantiated.
During the assessment period, two routine inspections by region based inspectors identified 7 violations.
Six Severity Level IV violations were identified involving f ailure to secure a vital area barrier, use of improper identification badges, f ailure to conduct key audits, failure to perform explosives detector performance' tests, inadequate lighting in two areas, and failure to retain certain records.
Licensee's corrective action on these items, which were identified in one inspection, were discussed in a management meeting during this assessment period.
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One Severity Level V violation involving failure to properly control a vehicle within the protected area was identified in a subsequent inspection. The large number of violations are not indicative of major programmatic br,eakdowns. An inspection conducted since the end of the assessment period (December 7-11, 1981) identified so similar problems.
Management attention is demonstrated by the prompt action to correct and t
prevent recurrence of the identified problems.
Site management is
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generally responsive to security program requirements.
Required reviews, audits and records are generally complete and show involvement by
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Corporate management. The security organization is well staffed with well defined responsibilities and adequately trained personnel.
Procedural adherence is good with infrequent personnel errors.
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Conclusion
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Category 2
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Board Recommendations
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None CPU Nuclear Corporation Comments:
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None.
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8.
Refueling and Major Outage Activities - NRC Evaluation During the previous assessment period, one region based inspection and
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frequent resident inspector reviews of refueling and outage activities identified two violations involving procedural inadequacies and procedural adherence. One of the violations involved a major breakdown of administration controls causing failure to remove control rod interlock bypass jumpers prior to control cell fuel reload. This violation received high level management attention by the corporate General Of fice Review Board and the Independent Safety Review Group.
During the current assessment period, one region based inspection of post refueling teaming and reload analysis was conducted. No violations were identified.
One scheduled and frequent unscheduled maintenance outages occurred during the assessment period. Considerable improvements in scheduling and coordination of outage activities were noted. This is due primarily to-the assignment of a full-time Programs and Controls Manager who oversees outage planning.
Scheduling activities generally addressed key outage and outage recovery items.
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Some problems in the area of control of contractor work were noted as evidenced by one violation involving blocking of torus vacuum breakers by contractor erected scaffolding and an event involving an airborne release of radioactive material from the radwaste building ventilation system.
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--One-region -based -inspec tion conducted-a f ter the asessment. period,
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identified some weaknesses in the area of control of design changes and modifications. These findings, which are under review by NRC management, indicated that the management of th.e design changes and modification
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_ Program is very_ fragmented with poor central _ control and review. Many.__
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procedures for the program are in draf t form and many are still being prepared.
Training on modifications completed during outages is sometimes delayed until just prior to startup, and drawing revisions are sometimes delayed.
This, together with insufficient management involvement in design change program, results in an occasional lack of coordination between engineering, construction, and operations staff during turnover of systems to operations control and in occasionally late implementation of revised
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'The~1icensee has a well staf fed corporate technical engineering group.
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This group is still gaining site specific familiarity resulting in
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considerable reliance on contractors for engineering support.
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Conclusion
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Category 2
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Board Recommendations
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In light of the planned extended outage involving numerous and diverse modifications, increased inspection activity
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should be devoted to outage activities particularly during the early portion of the outage.
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GPU Nuclear Corporation Comments We have had under aegelopment since early 1981, an integrated and improved system of' controls for work being done in the plant.
Improvements have been and are being implemented on an individual basis. The improved
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, system' is' scheduled to be in ef fect prior to the upcoming outage. The
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system will require a formal turnover to plant operations of all newly installed modifications.
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A completed modification, under this program, will be accepted based on the completion of preestablished conditions. The conditions specified for each modification will be formulated at a planning meeting after construction activities have been authorized. Preestablished conditions being addressed include:
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Training completed for operations personnel concerning the installed modification 2.
All applicable operating procedures revised 3.
Required spare parts identified 4.
Preventative Maintenance Procedures written and Preventative Maintenance schedule updated
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All applicable drawings revised 6.
Surveillance procedures and the Master Surveillance schedule revised The interfacing departments or divisions assigned responsibility for completion of the preestablished conditions will meet formally to verify and sign-of f that the modification can be put into service.
The following departments will be involved as appropriate:
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Plant Operations
- Oyster Creek Division 2.
Plant Maintenance
- Oyster Creek Division Oyster Creek Division 3.
Plant Engineering
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Technical Fune: ions 4.
Project Engineering
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Start-Up and Test
- Technical Functions thintenance and Construction 6.
Maintenance and Construction
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Training and Quality Control
- Nuclear Assurance Division 8.
Configuration Control
- Technical Functions Procedure No. 124 " System / Equipment Turnover After Modification" is presently being reviewed and revised to address the above program.
Additional procedures, if deemed necessary, will be developed.
In addition to this program, Plant Engineering will assign an engineer as the " plant contact" for each modification authorized through the Technical Functions division. The intention of the plant contact is to provide Plant Engineering awareness and follow-up of the modification such that appropriate documents, i.e., operations, maintenance, and surveillance procedures, vendor's manuals spare parts list, etc., are in the development stage as the modification is progressing.
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Page 17 9.
Licensing Activities - NRC Evaluation No specific assessment of licensing activities was performed during the
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prior assessment period; pertinent issues were included in other functional areas.
Licensing activities during the current assessment period included miscellaneous Technical Specificction changes, a review of TMI Task Action Plan items, a major license amendment changing the license to GPU Nuclear Corporation, and replacement core spray sparger design.
The licensee's performance and management capabilities were generally adequate; however, the timeliness of responses has been poor with a two to three month time delay being the norm.
Details of submittals are usually coordinated with the staff beforehand to establish requirements and clarity, and are generally good quality.
However, some submittals relative to the Systematic Evaluation Program (SEP) and the TMI Task Action Plan (NUREG-0737) were not always complete.1nd resulted in frequent requests by NRC for additional information. The licensee and his contractors have demonstrated adequate working knowledge of regulatory requirements and excellent level of technical competence. The licensee's staffing is generally adequate, but in view of planned modifications and possible SEP upgrade requirements, may require increases.
Conclusion
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Category 2
Board Recommendations
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None
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GPU Nuclear Corporation Comments:
The third paragraph of the evaluation states, "... the timeliness of responses has been poor...". While there have been cases where our response has been later than requested, we believe that a large factor in this has been the volume of requests and NRC's practice of setting unrealistic response dates.
Requests made for information frequently require complex studies or analyses to be performed before an adequate response can be prepared, reviewed, and approved by upper management. We will continue to respond in a timely manner and to formally request extensions where appropriate.
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