IR 05000219/1986003
| ML20140J441 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 03/26/1986 |
| From: | Eapen P, Napuda G, Oliveira W, Winters R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20140J424 | List: |
| References | |
| TASK-2.B.2, TASK-2.B.5, TASK-TM 50-219-86-03, 50-219-86-3, GL-83-28, NUDOCS 8604040332 | |
| Download: ML20140J441 (12) | |
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U.S. 1UCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-219/86-03
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Docket No.
50-219 License No.
DPR-16 Licensee:
GPU Nuclear Corporation Facility Name:
Oyster Creek Nuclear Generating Station Inspection At:
Forked River, and Parsippany New Jersey Inspection Conducted:
February 10 - 14, 1986 Inspectors:
X/d W. Oliveira, Reactor Engineer date
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D M R. Winters, Re' actor Engineer date jar /&d aWda,LeadReactorEngineer date
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Approved by:
k, MA4,h/,
Dr. P.'K. Eapen, Chie, Quality Assurance
' date Section, OB, DRS Inspection Summary:
Routine, unannounced inspection conducted on February 10-14, 1986 (Report No. 50-219/86-03)
Areas Inspected: Non Licensed Oparator Training and Off-Site Support to Oyster Creek Nuclear Generating Station by three region-based inspectors at Oyster Creek and two region-based inspectors at the Parsippany office.
Results: No violations were identified.
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DETAILS 1.0 Persons Contacted GPU Nuclear Corporation
~*J.' Barton, Deputy Director, Oyster Creek C. Chen, Design Engineer (Parsippany)
- R. Davidson, Operations Training Manager
- D. Dryden, Administrator Document Control
- R, Fenton, Plant Training' Manager
- V. Foglia, Operational Maintenance /PM & Surveillance Manager D. Grace, Technical Functions Engineering Manager (Parsippany)
- D. Holland, Licensing Manager
- S. Kempf, Maintenance, Construction and Facilities (MC&F) General Services Manager
- D. Larsen, MC&F Training Coordinator
- P. Manning, Field Inspection Supervisor
- R. Markowski, QA Program Development / Audit Manager
- E. Mislavsky, Inventory Control, MC&F Supervisor
- K. Quintana, MC&F Administration Support Manager
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' E. Roessler, Maintenance Training Supervisor
- P. Scalzo, MC&F General Administrative Supervisor
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- E. Scheyder, MC&F Director
- G. Simonetti Jr, QA Audit Manager
- W. Stewart, Plant Operations Manager
- J.~ Sullivan, Jr., Plant Operations Director
- J. Williams, Support Program Training Mancger
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U.S. Nuclear Regulatory Commission
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- W. Bateman, Senior Resident Inspector
- J. Wechselberger, Resident Inspector
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The inspectors also contacted other licensee technical and administrative personnel during this inspection.
- Denotes those present at exit meeting held on February 14, 1986.
2.0 Licensee's Action on Previous NRC Concerns (Closed) Unresolved Item 50-219/85-03-01: NUREG-0737, Item II.B.2., Design Review of Plant Shielding, states that vital areas requiring post-accident access be identified, and that dose levels and required si.ielding be deter-mined, so that the Time Integrated Dose (TID) for the duration of the ac-cident (30 days) does not exceed 5 Rems. Due to the use of conservative assumptions, the analysis for the main security building yielded doses in excess of 5 Rems for the. duration of the accident (30 days).
The licensee
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committed to reanalyze the anticipated exposure utilizing a pressure-de-pendent source term for the Reactor Building and taking occupancy factors for the Security building into account.
The inspector reviewed the licensee's final report for the Post Accident Shielding Study performed by United Engineers and Constructors Inc. This report included projected personnel radiation doses for post accident oc-cupancy in the Main Security Building. The post-accident dose assessments considered both the " Pressurized" and "Depressurized" Accident scenarios.
Relatively high. post-accident radiation levels, especially during the ini-tial 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, were predicted for both accident scenarios. The Depressur-ized Accident Scenario is the controlling event for the Main Security Building. The postulated TID for the depressurized Scenario in the Main Security Building fer the duration of the accident is approximately 3.6 Rems which is below the 5 Rem limit. Under the Pressurized Accident Scen-ario, the postulated TID is approximately 1.5 Rems which is also within the 5 Rem limit.
Based on the results of the reanalysis the item is closed.
(0 pen) Inspector follow Item 84-31-01: Response.to IE Generic Letter 83-28.
The licensee's Salem ATWS Task Force issued an Updated Status of Recommen-dations dated September 11, 1985.
It was noted that 17 of the 27 original recommendations were accepted as is by cognizant departments. The cog-nizant departments proposed alternatives to the other 10 recommendations.
.These alternatives were found to be acceptable by the Task force. The recommendations and the status of completion are tracked. An Engineering Assurance group, established approximately a year ago within. the Technical Functions Department (TFD), is responsible for the the actions assigned to that department. The current status of the recommendations assigned tc the TFD were discussed with the members of Engineering Assurance and the following was determined.
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Completion of The Quality Components List has been planned to a schedule with specific milestones and work is in progress.
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The scope of Vendor Manual Reviews has been established, control levels identified and a document control format developed. This review included equipment walkdowns, equipment history searches,
. vendor contacts and checks for any modifications.
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All plant procedures were reviewed to determine the population of vendor manuals in use or referenced.
Because of their classification 350 manuals of approximately 1400 will receive an extensive technical review.
It was determined that the-licensee's effort was adequate and progressing in a. timely fashio.
4 This item remains open and the status of this open item will be reviewed in future NRC inspections.
3.0 Non-Licensed Staff Training 3.1 General The purpose 'of this portion of the' inspection was to assess the ef-fectiveness of the licensee's non-licensed training. As a represen-tative sample, the inspectors chose the~ training' programs for instru-mentation and control (I&C) technicians, electrical and mechanical maintenance personnel, and equipment operators (E0s). The inspector noted that the' licensee had an initial INP0 review for accreditation of these training programs.
The effectiveness of the existing pro-gram was determined by reviewing the following:
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-Core Spray System I surveillance (procedure 610.3.105 Rev 6) by the I&C technicians. The technicians also conducted a design modification during the surveillance in accordance with Job Order.A ISM-30136.1.
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Shift turnover for E0s (0800 twice, 1600, 2400).
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Training records of two training supervisors, six instructors, four E0s, one I&C supervisor, six I&C technicians, two mechan-ics, one-Shif t Technical Advisor (STA), and one Quality Control (QC) inspector.
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E0 activities on all three shifts (filling the hydrogen analyzer; taking reactor and turbine building plant readings; filling the AIT-38-495 loop seal; stroking core spray valves V-20-92 and 94 in accordance with procedure 610.4.003 Rev 10; and blow down of an air receiver).
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Troubleshooting.the heating fan for the redundant fire building (preliminary action by electrical maintenance to determine if a job order (J0) is required).
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I&C Technician Initial Training Program for September and October 1985 including seven of the lesson plans.
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Three QA surveillance reports.
3.2 Details of the Review For each of the Job functions identified in paragraph 3.1, the in-spector reviewed the established training program, implementing procedures, qualification, and experience of personnel, qualification and training of instructors, quality of on-the-job (0JT) training,
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and the effectiveness of training as evidenced in daily activities.
The comments and evaluations from the trainees, line' supervisors, and instructors were also reviewed to establish how this feedback was factored into future _ training. The management and Quality Assurance (QA) involvement in the training area was assessed to determine their effectiveness.
3.2.1 Observation of Work Activities The inspectors witnessed the work activities identified in Sec-tion 3.1 above.
The activities were conducted in accordance with the procedures by personnel-knowledgeable in the require-ments of the procedures and technical specifications.
This was especially evident in the_following:
Instrumentation and Control (I & C) personnel in preparing for Core Spray System I surveillance and a design modification noted that the power. source for the test equipment may overload the system and cause an LC0 condition. Using another power source they were able to complete the prerequisites safely.
During the same surveillance, which had to be conducted within an hour in accordance with the Technical Specification, a step required a very minor change to the procedure. The I&C person-nel were aware that a change to the procedure, regardless how minor it may be, requires a documented change and its approval.
A further review indicated that the change to the. procedure was not necessary and the surveillance was completed successfully With regard to the stroking of core spray valves, the Equipment Operator (EO) was opening a vent valve when fluid leaked from the valve packing on to the E0's haid. He turned off the valve and quickly washed his hand and-had th6 hand checked by health physics personnel. The E0 returned after.being cleared by health physics personnel and continued to vent the system.
The inspector noted a concern as to the training E0s received in recording data from instruments that had expired calibration due dates and/or deficiency tags (short form). When questioned by the inspector, the EOs stated that they had not received any-training or instructions pertaining to instruments found with these conditions. The inspector discussed this concern with management in Operations, Operations Maintenance, and with the Training Department. The Operations Maintenance I&C-supervisor also dealt with the concern and issued a memorandum dated February 14, 1986 to emphasize his technician's responsibility to verify the calibration status of'the instruments surveille.
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The inspector verified that the instruments with expired calibra-tion due dates were calibrated except in one case where the in-strument did not require calibration.
A meeting of the I&C personnel was also conducted on February 14, 1986 for the express purpose of communicating the intent of the above memorandum.
The inspector was present at this meet-ing. This is an unresolved item pending completion of training of the non Licensed Staff and permanent inclusion of this train-ing in the~ respective training courses (50-219/86-03-01)
3.2.2 Training Policy and Progress
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The inspector performed a cursory review of the INP0 Accredita-tion Self Evaluations for non Licensed Operators (NLO), Electri-
. cal and Mechanical training programs, as well as selected proce-dures. The licensee policy and planning in procedures 1000-POL-2600.01 and 1000-PLN-2600.01 address the basis for and the com-mitment to training, on-the-job (0JT) training, and measuring program effectiveness. A key procedure is 6200-ADM -2682.01, Training System Development Process. The procedure establishes and describes the process used for developing training programs.
This_ process includes a Training Advisory Council; training in-terfaces, standards, and evaluation. The selected procedures and documents r' viewed are listed in Attachment A.
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. Training Department facilities had adequate classroom environment such as size, seating, lighting, ventilation and temperature con-
' trol; adequate training aids such as video tapes, movies, mock ups; and adequate training material ~such as lesson plans handouts, text books.
The Technical Resources Center has not yet been com-pleted. This was. reported in licensee's Self Evaluations for INPO Accredition. Also reported was the fact that the present staff is providing the minimum training required. Training im-provement or increase in training demands would require an in-
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crease in the staffing size.
The inspector reviewed the training records of supervisors and NLO personnel as well as training instructors. The training
' records were found to be current and complete.
The inspector also observed a group operator supervisor reviewing a revised procedure 6200-ADM-2682.10 Revision 1 entitled " Trainee Evaluation-once back on the job".
The supervisor was preparing comments to submit to Training Department.
This is an example of line organization providing comments to the training depart-ment as observed in practiced.
This indicated that the licensee has established formal means for obtaining feed back from the trainees and their supervisors.
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3.2.2.1 Non Licensed Operator (NLO) Training Program In 1983, the licensee established formal training programs and entry level requirements for Equipment Operators (E0s). and Rad-waste.0perators (RW0s). An analysis (Kepner-Trego) was also conducted'for the training program.
From this analysis the licensee. initiated Job Task Analyses (JTA) to be used.in the development of Job Survey Data. Operations management uses the~
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job survey data to develop the valid task listing. This valid task listing will be used in detail task analyses, which is scheduled to be completed by March 1986.
3.2.2.2 Maintenance Training Programs The self evaluation documents for I&C technicians, electricians and mechanics parallel the NLO self evaluation. The I&C Techni-can Initial Training Program for September and October 1985 was reviewed. Also reviewed were' lesson plans.
The initial train-ing program and lesson plans were found to be adequate. The per-sonnel interviewed rated the formal training as excellent. The DJT and requalification effort however needed ' improvements as well as a better selling job by management as to their benefits.
The electricians. formal training program is only a few months old and is rated as excellent by the electricians. They are looking
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forward to the documented OJT being implemented this year. The mechanical program is still being developed.
One weakness in the Maintenance Training Program is that the in-puts from the craft were not solicited. The licensee acknowledg-ed this weakness and will seek inputs from the craft.
3.2.2.3 QA/QC Interface With Non-Licensed Staff Training and Performance
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A QC inspector was observed to be providing adequate coverage for the core spray surveillance conducted in accordance with proce-dure 610.3.105, and the modification performed to JO AISM-30136.1.
The QC inspector was knowledgeable of the requirements and ac-ceptance methods. He was instrumental in resolving the question of whether the surveillance could be' completed without a minor change to the procedure.
Three annual QA surveillances of training were reviewed. The surveillances were detailed and the identified deficiencies were expeditiously corrected.
No violations were identified.
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4.0 Offsite. Support Staff The Licensee has established an offsite support staff and the administra-
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tive controls describing the responsibilities, authority and line, of com-munication for personnel performing the offsite support functions. To ve-rify these controls are in compliance with 10 CFR 50, Appendix B the in-spector reviewed three plant modifications packages that demonstrated off-site support for design, technical support, Quality Assurance, and Con-struction and the interfaces between the onsite and offsite organizations.
.The~ inspector also reviewed the as-installed configuration of the acces-sible portions of one of the modifications. The sequence of events for a
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modification project from inception to completion are as follows:
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Identification of Need. (either on or offsite).
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Evaluation (Technical, Regulatory, or Cost / Benefit)
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Budget Approval 4.
Baseline Design 5.
Preliminary Engineering Design Review (PEDR)
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Detail Design 7.
Operations, Maintenance, and Construction Review (OMCR)
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Release of construction 9.
Prepare Planning Package 10.
Preliminary Planning Meeting 11.
Operations Review 12.
Release for Work 13.
Final QA Audit
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4.1 Offsite Activities (Items 2 through 8 above)
Items 4,5,6,7,'and 8 of the sequence are the responsibility of the Techni-cal Functions Department located in the corporate office. However the OMCR meeting is normally held at the site to minimize lost time for opera-tions personnel, and to allow physical inspections should any questions arise concerning physical location of equipment.
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After budget approval the Technical Functions group determines whether design work is to be done by their staff or subcontracted.to an Architect Engineer. When the baseline design documents such as functional descrip-tion, interaction with other plant systems, feasibility, compliance with regulations (10CFR50.59), engineering. adequacy, and Piping and Isometric Drawings have been completed a PEDR meeting is called. The PEDR meeting chairman is a technically competent individual who has not been associated with the project. Other attendees are the project engineer and Quality Assurance representative as well as individuals from other affected organ-izations (Plant Engineering, discipline e.,gineers, Safety, etc.). Only
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one project is discussed at each meeting.
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Notice of a meeting is sent two to four weeks prior to the meeting and includes the documents pertinent to the project. After PEDR comments have been incorporated into the baseline design documents detailed design is started.
When the detailed design work is 70-90% complete Technical Functions calls the OMCR meeting (usually on-site). Notice of the meeting is sent two to four weeks prior to the' meeting, the baseline design documents are refer-
enced, and the. detail design documents are included. Attendees are ex-pected to obtain the correct revision of the baseline design documents from the document control center. The purpose of this meeting is to deter-mine that the modification can be accomplished as designed _. Considerations such as constructibility, operability, maintainability, and safety are ad-dressed. When the comments from the OMCR are incorporated and the detailed design is completed, the design package is released for construction.
Throughout this process the Design, Technical Support, Quality Assurance, and Construction organizations are encouraged to comment and assist. By participation in the PEDR and OMCR these organizations formally contribute to the projects.
4.2 On-site Activities (Items 9 through 13 in paragraph 4.0)
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Maintenance, Construction and Facilities (MCF) is responsible for the exe-cution of the design packages released for construction. MCF prepares the detailed planning packages including material requirements, crafts involved, quality requirements, radiological considerations etc..
When this planning is completed MCF calls a preliminary planning meeting to review the package. Attendees at this meeting include Plant Engineering, Quality Assurance / Quality Control, Operations, Start up and Test, Shipping
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and other affected organizations. Questions requiring design inp..t are referred to Technical Functions on a Field Questionnaire.
Prior to re-lease the package is sent to Operations with an Important to Safety Sheet (ITS) or a Not Important to Safety Sheet (NITS). Operations uses these sheets to document any restrictions imposed by the Technical Specifica-tions, FSAR or other requirements. When comments have been incorporated l
MCF schedules the work.
i The inspector reviewed the following design packages to determine the ef-fectiveness of the process described above in providing adequate reviews, interfaces between organizations, and in meeting regulatory requirements.
A.
Alternate Diesel Oil Supply Line.
B.
Startup Transformer Primary Breaker Logic Modification C.
Torus Room Door Modificatio.
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The review of A and B showed the PEDR and OMCR meetings were called within the time specified (two to four weeks).
From the comments recorded in meeting minutes, the inspector observed that the attendees had reviewed the_ documents furnished and raised legitimate concerns. Changes made in the design documents indicated that these concerns were adequately addres-sed.
In the case of C,.the size of the project did not warrant a formal meeting so comments were solicited by mail.
A review of t'he planning packages for the-above projects indicated that Operations had added restrictions to B and C.
For B, Operations required the work be done during an outage since this transformer must be available during oper.ation even though it is not safety related.
In the case of C, Operations required an individual to secure the torus room doors in case of an accident.
Inspection of the accessible portions of A showed the penetrations in the diesel generator building, supports and vehicle guards for the supply line were acceptable. Usually, the time from inception to readiness for con-struction of a modification is approximately one year.
A review of the Planning Package Approval Status Report dated September 2, 1986, showed that there were 86 packages in the system for the upcoming refueling outage scheduled to commence on April 6,.1986.
These packages included maintenance, modifications, and projects of various' complexities.
Of the 86, packages 22 were identified as "New".
Of the remaining 64, only 19 (approximately 30%) were on or ahead of schedule.
The licensee has recognized this situation and plans to add additional personnel to MCF to handle the workload.
No violations were observi 4.
4.3 Quality Assurance / Quality Control (QA/QC) Interface with Off-site Support The inspector noted during the review of offsite support that QA/QC staff was invited to PEDR, OMCR and Preliminary Planning Meetings. QA/QC person -
nel attend th'ese meetings and provide input with regard to Codes, Standards, and other quality related items. Quality Control (QC) is kept abreast of activities by participation in Operation's Plan of the Day meetings and'
the MCF Production Meeting.
In addition, QC performs a final audit of all MCF construction packages to assure that no vital inspections or tests have been missed.
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11-5.0 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompli-ance, or deviations. One unresolved item was closed during this inspection as discussed.in paragraph 2.0.
A new unresolved item (50-219/86-03-01)
identified in this report is discussed in paragraph 3.2.1.
6.0 Exit Meeting A meeting was held at the conclusion of the inspection on February 14, 1986, to discuss the scope and findings as detailed in this report. The.
licensee representatives (See paragraph 1.0 for attendees) acknowledged the inspection findings ~.
At no, time during;this inspection was written material provided to the-licensee by the inspectors.
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ATTACHMENT A DOCUMENTS REVIEWED 1000-POL-2600.01 (Rev.0) GPU Corporate Training Policy 1000-PLN-2600.01 (Rev.0) GPU Corporate Training Plan i
6231-PGM-2613~(Rev.2) Equipment Operator Initial Training Program 6200-ADM-2682.01 (Rev.0) Training & Education Department Training System Development Process 6231-ADM-2610.01 (Rev.1) Operator Training Instructor Indoctrination,
, Qualification & Certification Training Program 6200_-ADM-2607.01 (Rev.0) Instructor Evaluation 6200-ADM-2682.10 (Rev.1) Trainee Evaluation.Once Back On The Job (draft)
106 Operations Plant Tour & Turnover Check list 610.4.003 (Rev.10) Core Spray Valve Operability & IST
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l 610.3.105 (Rev.6) Core Spray System 1, Instrument Channel Cable & Test Equipment Operator Qualification I&C Technician Initial Training l
Program for September and October, 1985 l
l Lesson Plans Nos. 6234 PGM 2664, 2665, 2668, 2636, 2618, 2610 and 2604.