IR 05000219/1987024
| ML20236P570 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 10/29/1987 |
| From: | Bettenhausen L, Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20236P541 | List: |
| References | |
| 50-219-87-24, NUDOCS 8711180049 | |
| Download: ML20236P570 (52) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-219/87-24 Licensee:
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I Licensee:
GPU Nuclear Corporation
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Oyster Creek Nuclear Generating Station P. O. Box 388 Forked River, New Jersey 08731 Facility:
Oyster Creek Nuclear Generating Station Location:
Forked River, New Jersey Dates:
August 10 - 21, 1987
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Inspectors:
W. Bateman,. SRI - Oyster Creek (Technical Assistant)
l R. Blough, Chief, Reactor Projects Section IA (Team Leader)
j R. Brady, Reactor Engineer, Region I T. Dragoun, Lead Radiation Specialist, Region I D. Florek, Lead Reactor Engineer, Region I C. Hinson, NRR D. Johnson, Resident Inspector - TMI-1 J. Kaucher, Resident Inspector - Limerick 2 G. Kelly, SRI - Limerick 1 R. Pederson, NRR i
J. Sharkey, NRR ec o :
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R'. Bl o u g h I
l Di te Approved By:
dMN Dr. L. H. Betterfhausen, Chief, Projects Br. No.1 Date Inspection Summary:
An Integrated Performance Assessment Team inspection (830.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) was conducted by a group consisting of nine inspectors, a technical assistant, and a team leader.
The team performed detailed inspections in the areas of operations, maintenance, surveillance, radiation control and onsite engineering support. The inspection activities overlapped into QA/QC, offsite engineering support, and safety review.
8711100049 871109 PDR ADOCK 05000219 G
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e Inspection Summary (Continued)
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Inspection Results:
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. Strengths and weaknesses were identified in each of the five major inspection areas.
In many cases, areas noted by the inspection team as needing improvement have also been identified by the licensee. The licensee exhibits good attitude toward self-improvement and has a number of new or planned a
improvement programs which, if successfully implemented, should enhance the overall performance of Oyster Creek.
No violations were identified.
Paragraph 7 of the report provides a more detailed discussion of the inspection team's conclusions.
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InspectionSummary(Continued)
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TABLE OF CONTENTS Page 1.
Introduction and Overview..................
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Plant Operations...
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Radiological Controls....................
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Surveillance Testing....................
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Maintenance...
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Plant Engineering.....
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Summary..........
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Followup of Findings....................
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Exit Interview.......................
Attachment 1 - Persons Contacted Attachment 2 - Detailed' Activities and Documents Reviewed i
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DETAILS 1.0 Introduction and Overview 1.1 NRC Staff Activities
Region I periodically conducts integrated performance assessment inspections to enhance its understanding of licensee performance.
i The. team's essential elements and focus are described in paragraph 1.2 below. All licensees are subject to this type of inspection independent of past strong or weak performance.
This inspection process has proved beneficial in enhancing Region I's understanding of licensee performance.
The Oyster Creek facility was selected as a part of this effort for the following reasons:
(1) the plant' faces unique challenges due to its age, the lower state of the art in design and construction practices at the time of construction, and the lack of aggressive preventive maintenance in its early years of operations; (2) the rato of performance improvement over the past several years has been perceived by NRC to be very slow; and (3) NRC Region I perceived a recent increasing trend in operator errors.
1.2 Inspection Process The inspection included a review of plant operational activities by shift inspectors (24-hour coverage) and follow-up inspection on shift-identified items.
The essential ingredients to this process were observations of plant activities, and personnel interviews at the worker and first-line supervisor levels.
Follow-up interviews with supervisors / management and reviews of program descriptions /
procedures complemented the team's review of a particular functional area.
Program / implementation reviews, along with follow-up reviews on shift inspector-identified items, occurred in the following areas:
plant operations; radiological controls; maintenance; surveillance; and plant engineering. Within his functional area, each inspector was to assess effectiveness of training and assurance of quality.
The Team Leader met periodically with licensee management to inform them of preliminary inspection findings.
The Oyster Creek Senior Resident Inspector participated as a technical assistant to the team.
After the 24-hour coverage, shift inspectors on the back shifts resumed dayshift hours to review their assigned functional areas.
Random back shift coverage occurred during the course of the rest of the inspectio _ _.
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The following attributes were considered and examined during the inspection:
development'and implementation of management goals / objectives
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and how they are understood and implemented at all levels of the licensee's organization; level of understanding by workers / supervisors of potential
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impact of day-to-day actions on nuclear safety;
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attitudes of licensee personnel with respect to nuclear safety;
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involvement by senior management in day-to-day operad on of the plant;
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effectiveness of training, direction, guidance, and supervision by first-line supervisors; adequacy of staffing in light of planned accomplishments;
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role of QA/QC in monitoring activities and how their reports are
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used by plant management; role of' licensee in working with and overseeing contractor
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personnel; and, effectiveness of safety review.
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1.3 Plant Status and Activities During the Inspection During the inspection period, the plant operated routinely at full power, except for a brief power reduction during evaluation of a high bearing temperature on a feedwater pump.
Routine testing activities occurred. Also, there was relatively little safety related maintenance in progress.
Thus, direct observations in most functional areas reflected a period of routine activities with relatively little reactive efforts and few challenges from off-normal events. There was limited opportunity for inspectors to
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observe significant maintenance.
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2.0 Operations
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2.1 Scope and Review Operating activities were observed during the period August 11-20, 1987.
Backshift inspections, including observations between the hours of 2:00 a.m. and 6:00 a.m., were conducted during the period August 12-16, 1987.
The following control room activities were ob-i served:
staffing; turnover and panel walkdowns; control room en-
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vironment and access control; logkeeping and data trending; surveil-
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lance testing and maintenance interfaces; and, response to alarms
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a n'd other'off-normal conditions. The inspectors walked down portions of the following systems:
control rod drive hydraulic control units (HCU's);
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i core spray system;
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containment spray hect exchangers; i
standby liquid poison system
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emergency service water;
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.the isolation condensers;
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standby gas' treatment and secondary containment; and,
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automatic depressurization system.
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l-Adherence to Technical Specifications was verified.
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The inspectors interviewed operations staff members, assessed the effectiveness of QA and QC findings related to operations, and eval-uated the integration of the shift technical advisor (STA) into shift activities. As a measure of the effectiveness of communications between operations management and staff, the inspectors identified management goals and evaluated their promulgation and understanding at the worker level. The inspectors attended various daily meetings l-and assessed the interfaces and planning between operations and other l
site groups.
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The licensee's investigations of events in the form of incident critiques, deviation reports, and transient reviews (including the Plant Review Group) were evaluated by the team, as was operator re-J sponse to events which occurred during the inspection.
Finally, the material condition of the plant and its effect on safety significant equipment was assessed by the team.
2.2 Organization and Management i
2.2.1 Staffing
Operations staffing was judged to be adequate. A six crew j
training rotation is used. The shift rotation is a i
" counter clockwise" sequence that is being reevaluated by
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GPU management for back shift improvements. Operations l
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management was found to be very strong, both in communica-ting to the staff and by their consistent presence in the control room and plant spaces.. The use of a shift assistant alleviates the administrative burden on licensed personnel by (1) tracking plant' parameters, such as drywell'
leakage; (2) periodically reviewing controls on the use of y
operator aids and overtime; and (3) scheduling surveillance l
. testing.
Strict adherence to overtime guidelines was observed. De-viations have been rare and are. documented in the Group Shift Supervisor'(GSS) log..However, deviations when they occurred have occasionally been authorized by the Operations Manager, whereas procedure 106 and NRC Policy (IE Circular 80-02, NRC Generic Letter dated July 31,1980)
stipulate that the deviations from overtime guidelines should be authorized by the Director of Operations or higher (Observation --- See paragraph 8 for characterization of findings and intended followup).
l There is clear support among the operations staff for the GSS, and a recognition of his role as 'the hub of plant operations. The GSS was clearly in charge during normal
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operations and during transients witnessed by the team. A strong nucleus, consisting of the Director of Operations, the Operations Manager, and a Senior Engineer, assures the quality of plant management supervision, although the position of Operations. Control Manager is currently vacant and some of the staff are relatively young.
The use of daily meetings, such as the prioritization of new mainten-ance and the Plan of.the D.y meeting, serve to coordinate plant work among groups.
Consistent use of those meetings should better focus attention on important equipment defic-iencies. The team concluded that, within the operations organization, there was developing a reduced reliance upon any single individual and that the overall management of the group was strong.
2.2.2 Shift Technical Advisor The role of the STA is effectively integrated into shift activities, although the STA works a 12-hour rotation as opposed to the normal 8-hour shift.
The STA is typically in the plant or the main control room for 9-10 hours of the shift. He is utilized for trending of plant parameters, particularly for sensitive trends such as drywell tempera-ture, and torus water levels, which are indicators of pri-mary system leakage. The STA was found to be knowledgeable
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of emergency operating procedure (EOP) entry conditions and was generally observed to be a highly motivated individual.
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The STA plays a major role in developing transient analysis reports, such as report TAR-0C-019 prepared for the July 30, 1987, main steam isolation valve (MSIV) event.
The team found that the supervisor of the STA's, a Tech-nical Functions engineer, does not regularly visit the con-trol room, nor does he review STA logs. This was not ob-served to dilute the effectiveness of the STA; however, increased-supervisory presence could enhance STA indepen-dence (Observation).
2.2.3 Goals and Objectives Management's gcals-are portrayed by GPU corporate goals, operational group objectives, and management's philosophy via memoranda to the shift and by verbal communications.
While there were many formally stated goals which were not
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readily apparent from discussions with working level'per-sonnel, operators were knowledgeable of specific operational philosophy imparted by management. A sensitivity was confirmed by the team at the operator level for personnel errors, especially unplanned scrams caused by errors.
Also noted by the team was a sensitivity for the
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significance of balance of plant equipment, such as with the electric pressure regulator '(EPR) failure that occurred during the inspection.
Operators also espoused management's desire to not keep safety systems unnecessarily out of service, as evidenced by their response to a two-day outage of the core spray booster pump. The importance of technical specification equipment was also reflected by operator actions and con-
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firmed during team discussions, j
In contrast to the good sensitivity shown for avoidance of trips and for technical specification equipment out-of-service times, the team's observations outside the control room and discussions with non-licensed operations and maintenance staff lead to the following concerns:
(1) Personnel may not have a requisite feel for the significance with respect to plant safety of passive safety equipment which does not necessarily operate in support of plant generation, and (2) there appears to be a lack of risk perspective relative to identifying and caring for equipment that is especially important in reducing plant i
risk.
This was evidenced by the condition of the HCU's, equipment problems left unresolved (e.g., standby poison tank level), scaffolding erected over equipment important to safety (HCU south bank and outside remote shutdown panel), and fire hazards found in the new cable spreading area.
While not all attributable to the operations staff,
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-the direction and priority for work affecting safety systems is received from operations.
Management attention
'in educating the non-licensed worker level understanding of risk importance, and in establishing operations as a lead proponent of that philosophy is needed (Observation).
'2.3 Control Room Activities
.2.3.1 Environment and Attitudes All operators interviewed or observed by the team exhibited a cooperative and responsive attitude, a pride in their
' function, and demonstrated team approach to their duties.
The licensee has developed an atmosphere of accountability, in part by the effective use of discipline, and.this.is reflected by the professional demeanor of licensed opera-tors. A dress code is in use. Access. controls were evi-dent and effectively limited the number of personnel in the control room in spite of its small size. Business was generally conducted within the GSS office and operators were observed to remain at their respective panels.
Com-munications between the GSS and control room operators were clear and timely. When, for instance, if an operator left the confines of the at-control area, he would clearly com-municate that to one of the other two operators.
Noise levels were generally reasonably low.
2.3.2 Response to Annunciators and Plant Conditions The team considered operator response to annunciators to be excellent.
Immediate acknowledgement, use of alarm response procedures, and cognizance of the reason for alarmed conditions were all observed to be consistently achieved. The human factors layout of annunciator panels was an obvious aid in the observed good performance of operators in responding to alarms.
Examples that the team
observed included the intermittent feedwater pump motor
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bearing temperature alarms and a high local power range monitor (LPRM) condition.
Operators also exhibited a good feel for proper equipment performance. A core spray booster pump delayed start dur-ing a surveillance test was promptly detected by the con-trol room operator and this eventually led to the discov-j ery of a manual valve which was not properly throttled open. The failure of the electric pressure regulator was
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similarly identified by operators and immediate decision l
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making by the operator, in stopping the pressure control
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L evolution and transferring to the mechanical regulator, prevented a pressure transient and potential reactor scram.
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.These events'alsofinvolved appropriate involvement of
' supervision-(GSS) and notification ~ofLoperations management.
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2.3'.3 Use of Procedures
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The.use:of procedures,was generally' observed bylthe' team to
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be. appropriate, although an instance'was identified where;
an attachment from'a surve'illance test procedure.(out of
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the controlled set located in.the main control room) was used as a working copy but not' replaced.
This practice..
should be evaluated by operations management:(Observation).
All' licensee personnel.(including operators) displayed properLregard for green-colored controlled procedure'use.
The. team observed that updated copies of procedures were
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being used or were available throughout the plant in many
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activities, such as at remote shutdown panel locations and
'during maintenance and surveillance.
Operators were knowledgeable of entry conditions for, and
'use of,.the E0P's. Although, for example, the fact that bulk drywell temperature exceeding 150 F would (if not corrected). result in-a -reactor shutdown was not generally known from memory, the operators-interviewed by the team knew that an E0P entry condition was involved.
Consulta-tion of' alarm response procedures and interaction with the STA would eventually direct proper operator action for high drywell temperature.
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The re' gular use of Standing Order Number 1 was also obser-ved by the team.
Reference to the sta'nding order is useful in confirming various setpoints and proper system actuation
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levels.
Operator Aids (information posted in plant to assist the operators) are administratively controlled by approval of the Operations Manager, and regularly verified by shift assistants.
There are approximately thirty such postings currently being controlled.
Some unauthorized guidance, in the form of posted instructions or written information, was found in relatively few instances in the l
control room and in the plant. Additional formalization (i.e, typed information, removal of "grafitti," inclusion of an identifying number and removal of duplication in the file), is needed to provide a better controlled program which conveys management's desired philosophy of formalized, professional operation (Observation).
2.3.4 Plant Tours and Shift Turnovers The team observed a number of shif t turnovers during the inspection and found them to be of high quality, effective, and thorough.
Management has encouraged and supports the
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quality of turnovers by allowing for paid time to conduct shift' turnover.
Regular plant E0 tours were accompanied by team members throughout the reactor building, and outside at the diesel generators, and intake structure.
In response to NRC concerns for specific items not formally covered on tour sheets, the licensee added check of standby liquid poison injection valve continuity, and the normal
. position of a service water pump breaker transfer switch at the intake structure load center. 'Although personnel interviewed or observed were conscientious in covering all tour sheet items and in identifying changing /out-of-speci-fication conditions (an INPO finding and QA concern),
management needs to instill a more questioning attitude on other non-routine plant conditions (Observation).
Examples include scaffold location, gas bottle storage, housekeeping in normally locked rooms, and outstanding deficiency tags.
2.3.5 Logkeeping Logkeeping has been given high priority by operations management by virtue of their daily review of logs.
This priority was reflected by appropriately detailed entries as observed by the team. Although details regarding transients or significant events could not be assessed i
during the period of the inspection, the nun routine events I
that did occur were adequately described in logs.
Logs also received proper review by the GSS and by oncoming shift operators as part of turnover.
The team also reviewed the required reading material pro-vided for. licensed operator requalification which included NRC inspection reports and other appropriate documents.
Operators were aware of issues described in the material
and expressed an interest in and knowledge of NRC findings j
related to Oyster Creek, as well as events reported in
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Licensee Event Reports (LER's).
I The team also found consistent attention to and update of
the technical specifications log used to assure compliance with safety systems limits and operability requirements. A good training initiative observed by the team was the use of an operator in licensed training on the day shift to record technical specifications log entries. All such log entries were appropriately reviewed by licensed operators and approved by the GSS.
2.3.6 Plant Evolutions and Operator Response j
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A limited amount of equipment or plant transients were ob-l l
served by the team, but the response and control of opera-l l
tors were judged to be good.
An electric pressure regula-l
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l tor failure was promptly detected by the control room oper-ator while reducing power in response to a feedwater pump bearing problem.
The consultation of alarm response pro-cedures, awareness of plant conditions, and coordination of repair activities were appropriately accomplished. Another example where operator awareness was notable involved the-delayed start of a back-up core spray booster pump during a surveillance test.
Upon a trip'of the lead pump core spray booster, the operator recognized that the back-up pump did not immediately start and after approximately 10 seconds took manual control to initiate a pump start. Although some ensuing confusion was experienced as to whether a time delay was appropriate, later troubleshooting proved the operator's judgement to be correct and led to the discovery of a closed pressure equalizing valve, which should have been throttled.
Operators also responded to team questions regarding ap-propriate actions for high drywell temperature, electro-mat-ic. relief valve (EMRV) tailpipe temperatures, local power range monitor (LPRM) high power alarm conditions, and loss of secondary containment negative pressure. Although no events were observed wherein operators responded to the above conditions, operators correctly described recovery actions and walked through their response with team members.
No weaknesses in operator response to events were identified by the team.
2.4 Incident Assessments The team evaluated the licensee's programs and procedures to respond
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to, investigate, notify, and analyze plant events including spills, personnel error, and plant transients.
The licensee expressed a conservative philosophy with respect to deportability to the NRC, although no actual reportable events occurred during the team inspection. An example of the licensee's reporting philosophy was Licensee Event Report (LER) No. 86-09 that described a scram signal caused by nuclear instrument electronic noise with the core partially off-loaded.
The licensee reports these types of scram signals, even with the reactor defueled.
The licensee performs incident critiques in accordance with Procedure No. 106, " Conduct of Operations," using a prepared sheet to capture pertinent information regarding eventr, involving spills, personnel errors, and other conditions warranting critique. Although the procedure directs the GSS to conduct the critique, the Operations staff typically prepares the critique report (Observation).
The inspectors reviewed approximately ten incident critiques prepared during 1987 by the Operations group.
Other responsible groups also prepare critiques of events, but these were not reviewed.
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l i-The team specifically reviewed.the critique of the valve lineup. error for the' core spray booster pump.
The Operations Engineer.was tasked with gathering data and interviewing personnel to ascertain the cause l
of-the lineup error.
The event was traced to a maintenance repair
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performed on August 3, 1987, and inadequate verification of a throt-tied'open valve,'V-20-80, as required by Emergency Core Cooling System (ECCS) Fill.and Vent Procedure Checklist Figure 308 7.
In a short period of time, the critique had identified the activity and personnel respons1ble for the error, the effect and duration of the l
error on Core Spray System operability, primary root cause, and
appropriate corrective action.
The team concluded that the critique was effective and that the licensee's threshold for init.iating critiques was appropriate.
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The team also reviewed the licensee's post-transient review process conducted under Procedure No. 130.2.
The team reviewed a critique l
and report of the July 9,1987, failure of a feedwater regulating valve.
The. report described the convening of the Plant Review Group (PRG) and contained good root cause determination.
The report.also assessed that -prompt control room operator response prevented a reactor scram.
The team judged the report to be an accurate appraisal of operator response, equipment performance, and procedural adequacy. Although the PRG-was convened to discuss-the above event, l
the team found that the PRG is apparently under-utilized by virtue of the fact.that the group essentially meets only to review LER's and i
very few other plant events (Observation).
l The team also assessed the preparation by the Technical Functions staff of detailed Transient Analysis Reports (TAR's).
The TAR is prepared by the STA and is a thorough study of overall plant response to transient events. The team reviewed TAR-0C-019 prepared for the l
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July 30, 1987, Main Steam Isolation Valve (MSIV) closure scram, dis-l cussed the report with engineering personnel, and found the report to be complete and informative.
No unacceptable conditions were noted.
Finally, the licensee's system to identify potential safety concerns or
reportable occurrences using deviation reports prepared under Procedure
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No. 104 was evaluated by the team.
Deviation reports were observed to be routinely and appropriately initiated.
The team identified no particular
strengths or weaknesses associated with these reports.
The team did note t
that the licensee's Safety Review Manager is responsible to review all deviation reports and, therefore, the judgement of that one individual is critical in the assessment of deportability or safety significance.
2.5 Equipment Control and Conditions I
The team toured the plant regularly and observed the material condi-l tion of equipment and systems, as well as the control and identifica-
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tion of equipment status.
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Equipment Labelling i
The. team concluded that, while instrumentation was properly labelled, larger equipment (such as pumps, valves, fans,
and heat exchangers) was not'(Weakness).
Clear labelling
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of equipment can be an important factor in avoiding personnel errors and in enhancing in plant training.
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exception to the weak labelling was the core spray booster pumps, which were clearly identified, including effective use of flow arrows to indicate the normally expected direction of injection flow.
Valves are only identified by numeric codes that are under-
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stood only by use of a drawing.
Valve tags are small round
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metal tags with the valve number punched into the metal.
The tags are generally difficult to read in the darker, l
more inaccessible locations and, without a drawing, are not
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easily recognizable. An example found by the team was the diesel engine fuel oil supply and return line valves.
The team observed the licensee's practices for independent.
verification of' equipment configuration following mainten-
ance or testing specified in Section 10.0 of Procedure No.
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108, " Equipment Control." The team noted that independent i
verification was being properly accomplished for' instrument
root and block valves following surveillance testing.. Al-i though no actual independent verifications of larger valve
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. positions were observed, the team noted that the licensee's management needs to address the unique difficulty in ver-ifying the proper condition of throttled valves and valves in contaminated areas (Observation).
The core spray booster pump test observed by the team had as its root cause inadequate independent verification of a manual throttled valve, which was neither locked nor labelled /
identified as a throttled valve. The licensee's procedures relax the requirement for an independent operator to verify
"as-lef t" conditions in radiologically contaminated areas.
As seen with the core spray booster pump incident, opera-
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tors may inappropriately apply the above relaxation to noncontaminated areas such as where the core spray booster pump is located.
2.5.2 Housekeeping The team observed housekeeping in frequently traveled areas i
to be generally satisfactory, but in less traveled areas or upon closer inspections of equipmer.t, found poorer house-keeping conditions.
Some conditions potentially affected safety system operability, such as the following:
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ladders' propped against HCU's, nearby scaffolding
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erected. loosely, pressurized bottles stored between
HCU racks, and miscellaneous debris or tools hanging l
on scram inlet, outlet, and directional control i
valves; j
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scaffolding erected, but not currently in use, outside the chlorine building and near a remote shutdown panel; storage of a crane outside (near the in-take struc-
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ture) in close' proximity to a remote shutdown panel; and,
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various fire hazards stored inside of. the new cable spreading room.
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q Other housekeeping deficiencies.of lesser significance were observed in the reactor building equipment drain tank room shutdown cooling rooms, and the diesel generator building.
The condition of housekeeping, although promptly responded j
to by the licensee and acknowledged to be recently improv-
ing, was considered a weakness by the team.
Part of this
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weakness is the poor-control of gas bottles, equipment on rollers, temporarily stored equipment, and ladders
(Weakness).
2.5.3 Tagging Practices The team noted a number of equipment conditions that were not tagged.
Examples included a temporary variance to
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install pressure indicators on the containment spray heat exchangers; unterminated leads left over from the contain-ment integrated leak rate test (ILRT); and, temperature /
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leakage monitors for the isolation condenser valves.
The team also noted use of uncontrolled signs or information.
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Examples included:
standby liquid poison. tank I
capacity and concentration; marking of the letters "EQ" on
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electrical panels, termination and junction boxes; and, various instrumentation aids, such as marking the "Hi" and
" Low" sides of transmitters.
Such uncontrolled plant information may lead to personnel errors and indicates a degree of informality in conducting operations (Observation).
The team reviewed locked valve logs, switching and tagging, and other equipment control logs maintained by the GSS in the control room and found these to be controlled in ac-cordance with Procedure 108.
Relatively few outdated deficiency tags were found during plant tours and control room inspections.
The licensee's recent efforts to min-
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- imizeithe, number o'f outstanding or outdated. deficiency tags-
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on plant l equipment were:, judged to be effective and consis-tently' applied. An' example whereby operators promptly,
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identified an equipment deficiency. to supervision involved
.the torus water level recorder.- The recorder had exhibited fluctuating noise that made trending of level difficult.
-The deficiency.was discussed with operating pers'onnel ~and the-0perations Manager and the team concluded that;appro.'
.priate attention was.being directed towards repairing'the recorder.
2.5.4 Reactor Building Airlock and Fire' Doors
.The. team observed, that on a number of occasions during the inspection when the reactor building equipment' airlock was being used, the inner airlock. door was kept open when the airlock was~ not in-use. While not a. regulatory require--
. ment, the team viewed this as an imprudent operational practice, particularly since the outer door was found by' an inspector t'o have noticeable seal inleakage. The licensee
. responded' by. closing the inner door anc' proposing a - proce dure change to ensure. that the door is. closed when not,in'.
use. 'The team concluded that the. practice of leaving the
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inner door open was a long-standing one and' reflected an apparent insensitivity to the importance of secondary-containment integrity (Observation).
Minor fire door discrepancies were identified by the team and were promptly corrected by the licensee. These in-cluded:
tightening of the outer cable spreading' room doors
'to seal adequately; posting of a sign on the shutdown cool-ing room ' door as a fire: barrier because of unsealed floor
. penetrations within the room; and, investigation of a fire door at the southeast exit of reactor building elevation 23 found propped open for a short time on August 17, 1987.
In-general, fire doors were found to be clearly identified, in good condition, and few compensatory fire patrols were i
required during the period observea.
2.5.5 Inverted HCU Accumulators i
During inspection of the HCU's, the team identified certain water accumulators which had been inverted to preserve the piston seals rather than simply replaced.
In response to concerns raised by the team, the licensee contacted General Electric and verified the acceptability of this practice.
l The inverted accumulator shell is used to reposition the piston in an unpitted area of the shell. The practice is i
L recommended during HCU maintenance training and was l'
initiated as part of a 1983 performance improvement recom-I
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P mendationbyIGE. The practice mitigates.the'effect of pit-ting: experienced at the piston / wall. interface due'to non-
. movement over extended. periods of time and:significantly.
extends the life'of the cylinder. No further concerns.were.
l expressed by the team.
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2.6 Quality Interfaces
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.The team assessed QA/QC coverage of. operational activities, and-the significance and effectiveness of quality findings related to plant-operations.
QA last performed an audit of operating activities dur-
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ing August-October 1986. The audit appeared thorough ~and covered an
' appropriate scope of activity.
Quality Deficiency Report (QDR)'No.
86-055 was issued regarding fire brigade training for security force
. personnel,.this was subsequently corrected. 'Another nonconformance was-issued for a' recurrent weakness with logkeeping practices to-which Operations management has continued to pay close attention.
lAs followup to the issue of logkeeping, the team noted that the GSS,
.l control room operator, STA, and E0 logs were neat and legible and.
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that-- off-normal readings were consistently highlighted and explained where necessary. The team concluded that operating staff and manage-'
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ment were cognizant of the QA audit findings and'have taken appro-priate corrective action to prevent recurrence.
The team also noted that.a new QA' audit supervisor, with more than ten years of previous-operations experience, has been appointed during the past year.- This
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should strengthen the operational perspective and quality of QA
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audits.
l The team discussed the make-up, charter, and findings of the'0pera-
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tional QA group with the group's supervisor and four members.
The
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group is separate from QA audit organizations and observes in-line l
activities as documented'in monitoring reports (QAMR's).
The comple-
. ment of experience within the group is diverse.
The group supervisor discussed goals that include more back shift covera'ge, team inspec-tions, and better focused activities, The QA inspectors were not i
observed to be visible or involved in operating activities, possibly due in part to a lack of identification of the personnel as QA/QC on their hard hats.
2.7 Conclusion Operations were found to be strongly managed.
The responsiveness and performar,ce of the operations staff reflected a proud competent
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organization.
Management goals were effectively understood by the
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staff, particularly with respect to an appreciation for the signifi-l cance of personnel errors, unanticipated scrams, safety system outage
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time, and the importance of technical specification equipment.
The importance of balance-of plant equipment was also observed to be appropriately ccnsidered by the Operation staff.
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N 0perational management' spen'd a considerable amount of time in the.
M 2 control room and.on plant't'ours.
Operators exhibited l acute-awareness
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of plant status by responding well to casualties and alarming condi '
ti o n s'.
Operators. appropriately involve supervision and. management where. required.
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he The reporting and. analysis lof operating. events lis.at an appropriate'
. threshold'and effectively enhances management's awareness of' plant'
pro.blems, although the~.PRG appears to belunder-utilized.
Practices l.
relative to blocking / tagging and eliciting. maintenance and. testing.
y support were adequate; however,' more direction is warranted in the.
area of independent verification, particularly for' throttled valves.
Housekeeping in the more inaccessible areas of the plant and inatten--
tion to detail in housekeeping of accessible plant area requires an.
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. increased concerted management' effort.and is currently a-weakness-.
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The importance of passive and standby safety systems such as the
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HCU's,' standby' poison system, and secondary containment needs to be better defined for workers at all levels.
3.0 Radiological Controls 3.1 Scope and' Review-Inspection.in the areas of radiological controls and radiochemistry included reviews of organization and staffing, facilities and equip-ment, respiratory protection, ALARA', access' controls, and training, as well as. observations during conduct.of various radio' logical'oper-ations:and tours of the radiological control areas..The general.
-acceptance criteria for this area are 10 CFR Part 20, Section 6 of!
the Technical Specifications and related American National-Standards.
3.2 Radcon Organization
- l The Radiological Control (Radcon) Department on site. falls under the
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Radiological Controls Director.
The various functions in this H
department are described in Technical Specification 6.2.2, " Facility Staff" and Figure 6.2.1.
The Radcon Director repo-ts off-site to the Vice President of Quality and Radiological Controls with a " dotted line" accountability to the Vice President and Director - Oyster Creek.
Licensee management stated that the Radcon Department is administra-tively separated from site Operations and other departments to create an independence similar to that afforded to QA/QC. A stated benefit is that Radcon could make unbiased safety decisions.
How-ever, this arrangement requires development of effective relations and interfaces with other departments.
This has been moderately successful in the past, with progress in program improvements proceeding at a sica pace.
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a The high collective personnel exposures that occurred in the past two
outages have dramatically increased top management's attention to i
radiation protection.
Since late 1986, various personnel reassign-
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ments and new policies have improved interfaces, particularly in regard to the-ALARA program.
The Radcon Vice President was muted over to head the Maintenance, Construction and Facilities (MCF)
Department, which contains most of the work force.
The Technical Functions Department has issued new procedures that require ALARA-l reviews by the design engineer. Most of these changes are recent.and l
the long term effect is not predictable at this time.
l The licensee also conducted, for all supervision, a training course
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(Senn-Delaney) designed to create a general team spirit of coopera-tion between all departments. Top management has clearly recognized j
the need for good interfaces under the existing organizational ar-i rangement and the need to resolve impediments to progress.
The l
training course appears to have improved relationships between
departments.
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Unlike newer stations, the Radcon staff at Oyster Creek is not re-quired to meet ANSI 3.2 Standards.
Training and experience requirements were not clearly specified by the licensee for
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supervisory positions.
There was also some minor confusion regarding
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l job responsibilities.
Draft job descriptions did not always coincide
l with the incumbent's understanding of the job responsibilities.
In
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addition, several key managers were new, including the Radcon j
Director, the Radiological Health Manager, and the Manager of Radcon i
Field Operations.
Although the departme'1t appeared to be fully staffed, the inspector could not verify-the staff's qualifications q
with the exception of the Directors who met Technical Specification 6.3, " Facility Staff Qualification." The lack of clearly defined
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training and experience requirements and clear organization
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relationships is a weakness (Weakness).
New radiological engineer positions have been created in the MCF and Technical Functions departments.
These positions were filled by transfer of experienced individuals from Radcon.
This action indi-cates the level of concern and support for the radcon and ALARA pro-grams at Oyster Creek.
The MCF radiological engineer has been particularly active in implementing new initiatives, such as the new drywell access control point.
On the whole, these activities are beneficial but tend to diffuse the responsibilities of the Radcon Department.
Performance within the Radcon Department is achieved through verba-l tim compliance with procedures -- a technique adopted from the military.
The extensive and detailed procedures are kept up to date l
by the radiological engineering group.
Procedure revision and ALARA reviews appear to be the main activities of the radiological engineers.
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There is a radiological assessor conducting audits of the-site radcon program for the Quality and Radiological Control (Q&RC) Vice Presi-dent. ~These' audits were not reviewed by the inspector.
There are
- also a few radiological engineers available.at corporate headquarters i
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who occasional.ly support the site activities.
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Interviews with radcon technicians and supervisors indicate that the
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staff is experienced and technically competent. A few first-line l
supervisors are particularly knowledgeable in their technical field.
In summary, the radcon program at Oyster Creek station is undergoing extensive change and improvement.
This is attributable to direct involvement and action by corporate management and the station super-intendent. The-radcon organization, however, is not aggressive and appears primarily. chartered to conduct routine activities.
3.3 ALARA The exposures during the 1984 and 1986 outages pushed the station
.j annual total over 2,000 person rem.
Management reacted strongly in
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an attempt to reduce future exposures.
During the 1986 outage, the reactor recirculation pipes were chemically decontaminated to reduce radiation. levels throughout the drywell. A reduction factor of 3 was achieved.
Several task force committees were recently organized to identify ways of saving dose.
Some of these committees are:
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Radiological Awareness Committee
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Long-Range Planning Group l
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Work Simplification
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Managers.or management representatives from most site departments attend these committee meetings. A new drywell coordinator was appointed since work in the drywell is a major source of exposure.
Radiological engineers were added to the staff of the MCF and Tech-nical Functions departments.
A new drywell access control building is to be built to better control the number of personnel in the
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drywell at any one time.
In spite of these projects, the inspector noted that there is no person designated as ALARA coordinator.
In keeping with GPUN matrix organization, each department takes action to achieve the exposure reduction dictated by top management. There is no overall document or long-range ALARA plan nor are there any long-range ALARA goals or
objectives.
The procedure that described the ALARA program was
deleted during the last procedure overhaul.
Therefore, there is no
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overall guidance available to the departments conducting ALARA I
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activities.
This lack of overall coordination and definition of the i
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ALARA program together with the specific overall problems noted in
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the succeeding paragraphs (i.e., dose estimating, high " trigger" level, technician training and responsibility, use of goals) is considered a weakness (Weakness).
Each proposed outage job identified on the long-range plan has a dose
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estimate.
However, these estimates are not justified by careful
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analysis. A corporate radiological engineer, using information from previous outages, is actively. revising these estimates, and is cur-rently 10 to 20 percent complete.
Most of these major projects related to ALARA were recently initiat-ed, many in early 1987.
The impact of each activity will need review at some future date.
Another aspect of ALARA is the control of work via the Radiation Work Permit (RWP) process. All RWP's pass through Radiological Engineer-ing, who determine if a full ALARA review is required.
The trigger
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levels for ALARA reviews are quite high.
For example, the estimated
dose for the job must exceed 5 rem. ALARA reviews follow procedure 9300-ADM-4010.02.
The reviews that are completed by the radiological engineer'are generally quite good.
However, only about one in four
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jobs get reviewed.
The extent.to which the ALARA prerequisites were
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implemented could not be observed during this inspection since no
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substantial work subject to an ALARA review was in progress.
l Radcon technicians providing job coverage can stop work if they feel I
that adequate precautions are not exercised.
Interviews with tech-
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nicians indicate that they also use ALARA techniques but they have not been formally trained in ALARA nor is ALARA a formal responsi-
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bility.
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Facilities for mock-up training of workers are available on site.
This included items such as a control rod drive and a recirculation
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pump seal. Workers appeared to be sensitive to ALARA, particularly in the MCF Department.
i The Technical Functions Department, which provides engineering ser-vices and initiates most plant modifications, has made several changes to enhance ALARA. A new procedure provides ALARA design considerations for engineers (ES-007, "ALARA Guidelines for Configur-ation Changes").
Engineers are also required to walk down the project to obtain first-hand knowledge of the system and its radio-logical environment.
Policies are established requiring timely sub-i mittal of work packages to the site to allow adequate time for the radiological engineers to optimize ALARA for performing the work. As l
with other efforts, these changes are good but are very recent.
The exposure goal for 1987 is 300 person rem with 525 person rem targeted for 1988 -- an outage year.
The station total was about 270 person rem in July 1987 and projected to be near 500 rem at year end.
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This is'almost twice the 1987 goal.
For:the 1988 outage, radiolog-
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ical engineers Lestimate about 1200 person rem for. work identified so-far...It is probable that next year's goal will be greatly exceeded.
Station management was' advised that the goals are unrealistic, but.if properly used, goals are an' effective performance tracking method in:
the ALARA program. There is also a need to develop realistic long-range goals, which. considers the safety-related work that must be p
performed on aging equipment.
Exposure goals lneed to be assigned to.
the'various departments', with Radiological Engineering issuing. status
. reports using a computer program already:available on site. 'This
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would increase.the effectiveness of goal setting to reduce exposures.
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In summary, there are major ALARA initiatives proceeding on a broad front. However, management needs an overall plan to consolidate
' gains and provide actual analysis of proposed ALARA actions.
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'3. 4 Facilities and Equipment This area was found to be adequate.
Portable survey instruments, air samplers, and continuous air monitors were found to be_available in sufficient number and generally in good condition.
State-of-the-art whole body counting and personnel ' frisking equipment are in use at Oyster. Creek. A dedicated Radcon Instrument & Control (I&C) Group (separate from the plant Operations I&C group) exists to ensure-calibration of this equipment.
A group of ion chamber survey meters is provided at the RWP desk for issuance to workers who are accessing high radiation areas. These meters are required to be source checked before each use. However, all-meters are-source checked only by mid-shift technicians for use-the next day.
Due to the delay between the source check and field use of the. meter,.there is a possibility that the meter could become inoperative.
The licensee was advised to review the source checking practices (Observation).
The radcon counting room conducted adequate cross beta gamma analysis of air samples and smears. However, the gamma spectrometer was out of commission at the time of inspection and isotopic analysis of samples was being provided by the chemistry department.
i The calibration program for survey meters was reviewed by touring the q
calibration facility, reviewing selected procedures, and randomly j
checking inservice instruments.
The inspector noted that instruments
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are calibrated per ANSI N-323-1978. Whenever possible, the more re-strictive acceptance criterion of i10 per cent is used.
Calibration status of instruments in use is tracked with a computerized system.
However, the current system is somewhat cumbersome and the licensee plans to upgrade this system. One lapse in calibration was noted.
Specifically, the CAM and associated low volume air sampling pump l
connected to the vent in the respirator maintenance trailer was found j
to be c g -due for calibration by three months.
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LComputers were used at the' radiological controlled area (RCA) control'
points'to log personnel into'and out and to record. exposures.
Sup-
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porting software is available to' analyze these data and provide. dose'
trending by RWP number, job type,' date, job' site, and time of day.
Although analysis of~some of these' data.is'made available only to
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radcon personnel on a daily basis, wide dissemination.of these: data-F should'be.made to the rest of the organization and was recommended by-the inspector.
3.5 Material and Contamination Control The control. of radioactive material was found to be' adequate. Con-tamination and high contamination areas were found to be conspicuously posted and controlled with well-maintained access /.
egress points.
Due to minimal work inside these areas during the inspection, there was little opportunity to observe actual entry and exit of personnel and equipment from contaminated areas.
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Control of material outside contamination' areas was found to be
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generally good.
Bags of waste, used protective clothing, and con-g taminated equipment were generally labelled properly as radioactive material. However, the inspector.found two metal bins of contam-inated. torus clean-up equipment-that were not properly labelled. One was labelled with erroneous dose rate information and the other label
'was so badly weathered that it was barely recognizable.
The licensee immediately corrected these discrepancies, The. inspector noted that appropriate requirements for protective clothing were used. All individuals exiting the RCA must perform a whole body frisk. At the major access / egress points automatic com-
.puter-controlled " quick friskers" are provided. Shielded frisking-stations are also provided inside the reactor building near the work locations. However, the inspector noted that all four of the booths had background radiation levels that exceeded the maximum allowable, making it difficult and, in some cases, impossible to perform a proper frisk in that booth (Observation).
3.6 Radiation Area Access Control The inspector reviewed the licensee's RWP program, high radiation access control, and locked area key control.
The RWP program appears
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to be adequate.
RWP's are initiated by the group performing the
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work.
Radiological surveys, determination of protective measures, and (
issuance of the RWP are performed by the Radcon Field Operations Group. Workers are issued job specific RWP's when they sign into the d
RCA and are briefed on requirements for work in the area.
Standing RWP's are posted at the RWP desk and must be signed by workers using them.
Standing RWP's are reissued every month with updated radio-
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logical data.
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High radiation areas (less than 1000 mrem /hr) were found to be bar-ricaded and posted, as required. A tour of the locked high radiation areas indicated that the doors / gates, in general, were in good mate-rial condition.
Keys to the locked high radiation areas are control-led by the Radcon technicians at the control point-.
The inspector reviewed the sign-out logs and status board.
Two areas with very high radiation levels (TIP drive shield room and clean up filter sludge tank) have a second locked door.
The keys to these doors are-maintained by the Group Shift Supervisor (GSS) and are only issued to senior radiation control technicians.
The inspectors were concerned that it was possible in some areas to physically circumvent the barricade. The instances were pointed out to the licensee.
This, in itself, does not constitute a loss of positive access' control. There was no indication that any barriers had actually been circumvented.
However, continuous vigilance by the licensee is required to prevent subversion of the access controls (Observation).
3.7 Respiratory Protection The respiratory protection program is administered by several differ-ent groups within the plant organization.
Respirator maintenance and normal issuance is performed by a group that is under the MCF Depart-ment.
Respirator fit testing is under the Radiation Health Manager, prescription of use and back shift issuance is performed by the Field Operations Group, and respirator use training is performed by the General Employee Training (GET) group. The responsibility to admin-ister this program rests with the Respiratory Protection Supervisor (RPS) or his designee. A weakness in the program is that the RPS is not onsite (Weakness). A RPS located at TMI is responsible for Oyster Creek and TMI facilities. A radiological engineer at Oyster Creek is designated as his representative when the RPS is not on site. The inspector noted that the RPS designee and some of the training instructors do not meet the experience specified in NUREG 0041.
The inspector also noted that the off-site RPS no longer performs an annual audit of the program. The team believes that a technically
strong RPS is needed on-site to coordinate the program, particularly when several organizational groups have responsibilities for parts of the program.
Some good practices were noted in the program as follows:
(1) the non-radiological respirators are incorporated into the maintenance program, (2) use of support molds in face pieces of respirators prevents deformations in storage and (3) 100 per cent of respirator High Efficiency Particulate Absorbers (HEPA) filters are tested.
In general, the respirator maintenance program was found to be strong.
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A potential for the contamination of the breathing air supply from a bottled gas station near the compressor's house air in-take was
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noted.
Bottles of nitrous oxide, argon, acetylene, propane, and other gases are in use at this station.
The distribution tubing for these gases is routed through the compressor house. Although a safety review of this bottled gas station was performed, there was no
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evaluation of the potential impact of a noxious gas leak on the
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breathing air system.
The licensee has committed to formally review
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and document this risk and take any appropriate action (Observation).
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3.8 Training L
The review of this area consisted of interviews with selected person-
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nel, inspection of the training facilities, and reviews of selected l
lesson plans and instructor qualifications.
l An extensive technical training program to support technician qualif-
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ication is provided on site.
Field Operations RCT's and chemistry technicians are qualified by a three-tiered qualifications program.
I Cyclic training is provided as part of the requalification program.
l The inspector observed that there appears to be no incentive for the
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technicians to do well in the cyclic training. Although the technicians must pass their requalification exam, there is no requirement to pass the cyclic quizzes. The licensee has also identified this as a problem in the training program and is investigating corrective measures (Observation).
Radiation Health Technicians (RHT) perform the respirator fit test-ing, whole body counting, and dosimetry issue functions at Oyster Creek. The RHT's have a one-step qualification program separate from the Field Operations RCT's qualification.
Both of the supporting training programs are performance based and concentrate on teaching only the skills needed to perform the required tasks.
During the interviews with the RHT's and RCT's, the inspector noted a lack of breadth in technical knowledge.
Given compartmentalized functional responsibilities in the Oyster Creek organization, it is important that training provide sufficient breadth of knowledge such that there will be overlaps, rather than gaps, between interfacing functions.
The current training did not appear to the inspector to be providing this overlapping knowledge (Observation).
A good practice was noted during the review of the Technical Train-ing Department.
Recently, the training staff developed a question-naire and surveyed the plant personnel on their awareness of ALARA techniques and principles.
Based on the results of this survey, an inter-disciplinary ALARA seminar / workshop has been established as part of the cyclic training program.
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' 3.91 Dosimetry-p.x
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- The inspector. interviewed technicians and supervisors in the
' dosimetry issue program, observed plant practices requiring the use of ' dosimeters, and. reviewed dose calculations of; two recent skin _
contaminations _from hot particles and MPC-br calculations'from whole'
a, body; counting results. The program'is generally adequate.
LThe' inspector noted that the technician's'and' dosimetry super ;
' visors interviewed showed a. lack of knowledge of the limitations of-c the.TLD system in use'at Oyster Creek. This lack of knowledge was
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highlighted by a poor practice noted by the inspector.
During-it
General Employee Training (GET), workers were; instructed toiturn-their TLD' badge around when-taping it to their. protective clothing.
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(This was:done to protect.the paper label on the badge' holder. : None.
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Lof the individuals interviewed understood that this practice adversely' effects the response of the.TLD to. beta radiation.
The
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licensee is investigating corrective measures (Observation)..
,.L 3.10 SummaryL A positive; attitude and technical competence is evident throughout
'the Oyster Creek Radcon organization _.- A strong effort by upper.
- management in recent months to develop a broad base of support and
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participation in the-Radcon program has already achieved some'
' success. However, the matrix style of organization has resulted in the " committee" approach to resolving problems. There is'no' clear
. management. responsibility or accountability for the program. As a further consequence, there is no technically strong group onsite or.
at the corporate. level who coordinates and consolidates the various
- ef forts.
This has resulted in a slow rate of progress with the per-manency of Radcon program improvements remaining uncertain.
4.0 Surveillance Testing 4.1 Scope and Review The-inspector reviewed the surveillance activities conducted on site to' determine the adequacy of the program, the knowledge of the indi-viduals participating in the organization, the attitudes of the per-sonnel toward plant safety, the interfaces between the work groups involved, the general quality of the work performed, the perception of;the working personnel in the overall material condition of the plant, the review and use of the results of the surveillance test performed, and the interaction between workers and supervision in the performance of the assigned task.
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4.2 Introduction During plant operation the licensee initiates surveillance activities from four major sources. These include performance of technical specification required surveillance based on the Master Surveillance Test Schedule; the performance of calibration of installed plant instrumentation, which is required to verify that technical specifi-cation requirements are met, under the Technical Specification Supporting Installed Instrumentation List (TSSIIL); the performance of calibration on other installed plant instrumentation under the preventive maintenance (PM) program; and, surveillance activities performed following maintenance.
Due to the matrix organization of the licensee, the surveillance activities are planned, implemented, and reviewed by several differ-q ent organizations.
Plant Engineering retains the program to assure that the technical specification (TS) requirements are translated into procedures; Plant Material assures that the TS surveillance are scheduled and completed as required per the technical specification; and organizations such as Operations and Maintenance, Construction &
Facilities (MCF) personnel perform the actual surveillance. The completed surveillance are then reviewed by the appropriate person-nel in the above organizations.
The inspector interviewed the personnel assigned the job task in the respective organization and assessed their involvement in the program by review or observation of current work activities.
4.3 Technical Specification Surveillance
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The Plant Engineering organization has developed a technical specifi-cation surveillance procedure cross-reference document and maintains
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the document current. When a Technical Specification (TS) change is I
made, the cross-reference is revised.
The Plant Engineering organ-ization is also aware of the proposed changes so that when approved, TS changes do not come as a surprise.
The cross reference has recently been reviewed in its entirety by the responsible engineer to assure that the listing is complete.
The Plant Material organization is responsible for the development and implementation of the Master Surveillance Test Schedule.
The licensee utilizes a combination of computer generated / manually ad-justed schedules to assure that surveillance are performed as re-quired. The licensee's scheduling philosophy is conservative.
The licensee does take credit for post-maintenance surveillance testing but, for purposes of developing the next required date, usually reverts back to the originally scheduled date. This assures that the TS-required surveillance are met as required. As a result, since the system was implemented, the licensee rarely has a missed
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surveillance. The licensee develops and issues a weekly schedule for performance of. surveillance to the responsible organization for implementation.
Daily and weekly surveillance are the responsibil-
. ity of assigned organizations and are scheduled by the assigned
. organization. When completed, the scheduled tracking sheets are
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returned to Plant Materiel to update the computer-based schedule.
The Operations and MCF Departments implement surveillance. Opera-tions develops its own weekly. schedule of surveillance based on the Master Surveillance Schedule (MSS), as well as the daily and weekly surveillance at the assigned shift level.
A complete. set of sur-veillance procedures for the week are drawn from the' Procedure Con-trol Department, serialized and plac'ed in the GSS office for imple-mentation per the schedule.
The Operations Maintenance organization is responsible for performing I&C, electrical, and maintenance surveillance.
This organization is an on-shift Core Group which usually consists of a supervisor, two to three'I&C' technicians, one to two electricians, and one or two mech-anics.
In addition to performing surveillance, they also perform preventive and corrective maintenance of an immediate nature.
The Operations Maintenance organization also develops its own weekly schedule for performing surveillance and assigns the surveillance for completion on a specific shift.
The Operations Maintenance organization has developed a priority of work types to be accom-plished (technical specification surveillance is higher than preven-tive maintenance).
Its principal goal is to support Operations.
The individuals are aware of technical specification importance and are aware of the immediate need for for the GSS to know if a surveillance is not satisfactorily completed. The individuals interviewed con-sidered management support to be generally acceptable.
All completed surveillance are reviewed by the GSS.
Responsible test organization management also review appropriate surveillance.
The scheduling individual also reviews the completed surveillance to determine if the surveillance performed is complete and satisfies the TS requirement for scheduling purposes.
Following completion of these reviews the supervisor of Operations Engineering reviews the completed package.
If the completed packages
contain information concerning inservice testing (IST), the results are forwarded to the appropriate individual for updating the IST program.
Based on interviews with assigned personnel, the individuals were
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aware of their responsibilities and interfaces with others. The
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communication channels were apparent and a positive attitude was demonstrated.
Questions from the reviewers based on their review of
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I the complete package were resolved with the affected party.
Rarely did the reviewers find serious problems with the completed packages.
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4.'4-Technical Specification Supporting Installed Instrumentation
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The;responsibil_ity for implementing the Technical Specification,Sup-porting; Installed: Instrumentation (TSSIIL); calibration is Operations-Maintenance.
Schedules are~ maintained, updated,'and.statused on a-monthly basis. Management awareness in.the TSS11L: program is also
.evidentLin. the tracking of the TSSIIL. surveillance.
The licensee
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treats-these items in a manner similar to technical specifications and require; the.same 1;25 interval factor limit on performance' of-
- calibrations.
Individuals tasked with performing TSSIIL activities.
are aware of their;importance..If a TSSIIL is found 'out of calibra -
tion,-a. deviation. report is required.
As part of the' corrective action, a review of completed ' surveillance which relied on the out-of-calib' ration installed plant instrumentation is checked.
I&C history cards are maintained for all plant instruments and are updated'following performance of(a calibration.
Supervisory person-n.el periodically review the completed cards for proper ' updating.
The-TSSIIL program, while effective, relies on the I&C technicians to individually determine the specific 11fted leads while performing the calibration. This does not result in a positive control of lifted'
leads. While the licensee has not had much difficulty.with this, the licensee is' planning to formalize the specific. lifted lead-identification (Observation).
4.5 Preventive Main'tenance Calibration During the inspection, inspectors noted that several installed instruments displayed calibration stickers that appeared to be out of date or lacked any sticker.
The licensee utilizes calibration
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stickers on instruments but relies on the I&C history cards as the-formal-system to capture calibration activities. One example in the reactor building was noted and several in the new radwaste building were identified. The reactor building instrument (IL-09) was in calibration, but the sticker either fell off or was'not put on.after calibration.
However, the instruments in the new radwaste building were not yet incorporated into the preventive maintenance (PM)-pro-gram. These instruments are not part of the TSSIIL program.
The licensee will include these instruments in the program.
The lack of inclusion of the new radwaste building instruments in the program is considered a weakness (Weakness).
4.6 Calibration of Measurement and Test Equipment
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The inspector intervieweci personnel involved with control, calibra-tion, and issuance of measuring and test equipment.
The current calibration lab is staffed with one licensee and two contractor personnel.
The current staff has very experienced personnel (approx-imately 20 years per man) in calibration of test equipment.
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The licensee is planning to eliminate the use of contractors in this function and to utilize GPUN personnel. The licensee will begin training senior I&C technicians to replace the contractor for this function, and plans to rotate personnel. This has the potential to degrade the calibration laboratory. Careful management planning is necessary to perform this transition (Observation).
The calibration-laboratory maintains control over issued instruments.
Good records of issue, job use, and return are evident.
Personnel are aware that. equipment must be checked on issuance and again on return.
If returned equipment is not in proper working order, the job must be re performed.
In addition, if the test equipment is determined to be out of calibration, all jobs that it was utilized in must be assessed for impact.
4.7 Surveillance Witnessing
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The inspectors witnessed several surveillance tests during this l
inspection, including several runs of 610.3.105, Core Spray System /
Instrument Channel Calibration and Test; 610.4.002, Core Spray Pump
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Operability Test; and, 651.4.001 Standby Gas Treatment System. The tests were effectively coordinated and properly implemented.
Per-sonnel performing the tests were knowledgeable of their function and the importance of meeting the test requirements.
This was evident by the licensee's response to the test criteria failure during the per-formance of 610.3.105.
The back-up booster pump did not auto start in the time period perceived by the operator and was manually started.
The licensee immediately took action to identify the cause of the failure and performed the core spray pump operability test on the
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unaffected portion of the system.
The licensee subsequently deter-mined that a bypass valve around the core spray check valve was in the closed position.
This affected the test but not the ability of the Core Spray System to perform as designed.
Subsequent to the completion of the pump testing described above, a review of the documentation was undertaken.
During this review, which occurred prior to first level supervision review, the inspector noted that a deviation report had not yet been written.
Following this discussion, the inspector determined this matter was also being pursued by the licensee.
The licensee subsequently developed the i
report.
4.8 Miscellaneous Observations The inspectors noted that scheduled technical specification surveil-lance is rarely missed.
The licensee does utilize overtime to accom-plish some surveillance activities.
For example, the core spray test witnessed involved coordination of more I&C technicians than are
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Th's, the use of overtime was required and normally on shift.
u planned to accomplish the task.
The use of overtime is not excessive, however.
The inspectors noted that the licensee has initiated a computerized trending system for the Technical Specification (TS) Table 3.1.1,
" Instruments." Data from approximately the last six months has been trended. The development of such a program is considered a positive
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contribution to safety.
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The licensee also treats a number of surveillance activities on non-safety-related systems as if they were technical specification required. The basis is that management considers these important for plant operation.
The inspectors determined that QA has reviewed the surveillance pro-gram and that prior audits had been accomplished with the identified QA finding resolved.
The licensee QA audit organization had recently initiated an audit which includes the surveillance program. However, due to the incomplete audit status, no conclusions could be drawn.
4.9 Conclusion The licensee's surveillance activities are effectively controlled.
The licensee has developed programs to assure the required surveil-lances are performed and reviewed. The personnel oerforming the surveillance have the safety insight to immediately inform the GSS when a problem exists.
The persons performing the work are knowl-edgeable. The communication channels among the various organizations are open and frequently utilized. Team work is evident.
The trend-ing of results is a positive sign.
5.
Maintenance 5.1 Scope and Review Plant maintenance programs were reviewed to determine their effect on the safe operation of the plant.
The NRC team members witnessed ongoing maintenance activities and discussed maintenance-related activities and administrative controls with appropriate personnel.
Interviews were conducted with technicians and craftsmen in the MCF division, including electricians, mechanics, and I&C department per-sonnel.
Personnel that interface with MCF workers were also con-tacted to evaluate interdepartmental coordination.
Maintenance department training for craftsmen qualified to perform maintenance on safety-related equipment was evaluated, as well as the Quality Assurance / Quality Control (QA/QC) involvement in maintenance activi-ties.
The impact of the maintenance backlog on safety-related equip-ment was also reviewed.
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.'5.2 Organization-
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Maintenance. activities at Oyster Creek Nuclear Generatio'n. Station (OCNGS) are controlled by three overlapping organizations, the Plant
~ Materiel.' Department; the Operations' Department, and the Maintenance,;
. Construction and: Facilities (MCF) Division.. The> Production Depart-
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ment. (craft workers)'.is part :of.MCF.
The Plant Materiel Department controis-the preventive maintenance (PM) program. Actual PM's.are~-
accomplished'by either'MCF craft personnel or:a special staff of MCF-craft personnel referred.to asLthe operations shift maintenance-staff.- Corrective ~ maintenance and major' modifications'are accom-plished by the Production Department.
Some minor corrective'mainte-nance termed "immediate maintenance" may be: accomplished by the operations, maintenance staff as the need arises.~ The MCF Division
- (production) reports to a corporate vice president at GPUN headquar-ters.. Plant Materiel-and Operations report to.the on-site. Director, OCNGS'.
Plant Materiel.and MCF are responsible to review and prioritizescor -
rective maintenance work'considering Operations Department input.
TheLMCF staff ~ accomplishes overall planing, scheduling, and specifies
- the post-maintenance test requirements.
Plant Materiel has taken on-an. emerging responsibility for equipment' failure trending as dis-cussed in 5.6 using the Reliability Centered Maintenance Program ( RCMP).-
This' matrix-type. organization, while somewhat unique in structure, is considered by the licensee to be advantageous in that it provides
" checks.and' balances over maintenance activities..The inspectors observed that this organizational structure, combined with the com-
.plexity. of the MCF work planning procedures-and. methods, results in an extraordinary paperwork burden on-the personnel performing the work (i.e., workers and supervisors).
The individual job foremen become heavily involved in administrative duties, which detract from time spent actually supervising work activities.
This was considered by the.. inspector to be a program weakness and could possibly be a significant contributor.to the backlog of corrective maintenance items (Weakness). The inspectors did acknowledge that the licensee is in the process of examining ways to simplify the maintenance process.
5.3 Work Control Control of maintenance activities at OCNGS is accomplished through various procedures and work control documents. The short form (com-
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bined work request and job order) is the primary vehicle used for the
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majority of corrective maintenance activities.
This form provides for various approvals, checks by QA/QC, Radeon, Engineering mainten-
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ance scheduling, and for specifying post-maintenance testing activ-ities.
This process at OCNGS is being upgraded by use of the GMS-II
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computerized-maintenance system.. Upon full: implementation,.which is-
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currently estimated-as early.to mid-1988, the system should result.in
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more accurate and complete processing of. work-requests;and issuance
.of more usable job orders..The short. form : system :is intended to be
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replaced.
Preventive maintenance (PM) is controlled by a system-of PM check sheets which are. accomplished either by Operations or MCF' personnel.
.This: system was reviewed by'the. inspector and found-to be generally-
- complete and acceptable. The:-: licensee-has1a very small percentage of. non-completed PM's.and,this is considered to be a strength.of thel maintenance department 5.4 Maintenance Activities
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5.4.1 Area Radiation Monitor (ARM) Repair An inspector witnessed back shift operations maintenance personnel accomplish the repair of one string of: ARM indi-y cation;and trip units in the-control: room.
The repair
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consisted of one-for-one replacement of the " ribbon cable,"'
essentially the. power supply ' cable, for each _ individual unit.. Maintenance personnel were aware'of the significance
.of.the equipment and accomplished appropriate post-main-
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tenance testing, which consisted of verification ofl con-sistency of "before and after" readings..The Job was accomplished via.short form 43098 and wiring and cable harness disconnects and reconnection were documented on the troubleshooting forms from OCNGS Procedure 105, Appendix D.
The inspector questioned the mechanics about the avail-ability of a more formal generic I&C maintenance procedure that would= incorporate standard wiring disconnect / reconnect logs. They indicated that use of the troubishooting form was standard practice. Altho. ugh not a rigorous control, the troubleshooting form appeared adequate for this purpose, given the simplicity of connecting a ribbon cable.
The mechanics were using a vendor manual for the ARM's and seemed unaware of any formal markings that would indicate a controlled or up-to-date manual.
Later questioning of QA personnel indicated that manuals at DCNGS were controlled and that a check in the CARIR's system by maintenance foremen prior to work start would confirm that the OCNGS generated cover sheet in the individual manuals was current.
The inspector had observed this cover sheet in the manual and it indicated a properly controlled manual.
The station is also in the process of final approval of Administrative Procedure 107.3, " Technical Manual Use and Control." Overall, this job was appropriately coordinated with operations personnel and conducted in a safe manner by the operations maintenance staff.
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J 5.4.2-Poison Pump Prevehtive Maintenance l
The;in_spection team: witnessed performance of' Preventive Maintenance Procedure 1542'and 1543.
These procedures i
involve ia visual. inspection. of: the Standby Liquid Control
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System. poison. pump piston shafts 1for boric acid'. buildup.
.The back shift operations / maintenance? mechanics performing
'this.' task'were' sensitive to the; safety importance of theses pumps, were familiar with the job,: and demonstrated good :
maintenance' practices in performing this activity. The'
operations / maintenance-supervisor provided sufficient.
. oversight to. ensure the; task was properly performed.LNo weaknesses were noted in the performance of this-
. maintenance? activity.
The team noted that the. majority of:
plant preventive maintenance and-surveillance testing was b
performed.by the back shift operations / maintenance crew i
which consisted of two mechanics :two electricians, and at.
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least two'I&C technicians.
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L5.4.3
. Core Spray Booster Pump Relay Repair-During the inspection, the operability test of Core' Spray Booster Pump Failure Logic System 1 resulted in an apparent surveillance test failure (procedure 610.3.105, " Core Spray System 1 Instrument Channel Calibration and Test"). The lice'nsee's troubleshooting efforts resulted in the replace-ment of an suspectedly faulty. relay in the_ system logic.
Appropriate procedures were used in troubleshooting the apparent failure and relay replacement.
The licensee's responsiveness to inoperable technical specification asso-ciated equipment repair was considered a strength.
5.4.4 hdraulic Control Units Scram Control Valves Packing Adjustment On August 15, 1987, maintenance was conducted on the CRD Hydraulic Control Units (HCU's). This corrective maintenance was in response to a NRC team member finding that many packing gland nuts were loose. The maintenance checked and tightened the packing gland nuts on the V-126 and V-127 (scram inlet and outlet) valves. A procedure was generated specifying torque requirements and included comments from the on-site GE representative.
The foreman briefed both the machinist and the QC inspector prior to performing work. A visual check was performed on all the HCU's and deficiencies were noted and corrected.
No unacceptable performance or poor practices'were noted.
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5.5i Maintenance, Backlog'
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During thellast-Systematic Assessment of Licensee Performance (SALP)
. period, it was'noted:that a large backlog of corrective maintenance -
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t items, existed.
.It'. appeared that this.large; number of items was-being kept constant'and not much progress wa's being-made in reducing the backlog;to more acceptable proportions. The-licensee assigned.a=
. senior.managerLto evaluate'the problem and take-action to reduce:the
' backlog or/ recommend ~ actions to correct this. situation.
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Licensee review of: individual maintenance items' revealed some dup-
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.licity in the short. form tabulations.
These short forms were 'either
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combined or deleted when'similar_ work requests existed.- Some of the backlog.was due to:short forms that wereLcomplete'but needed admin-
.istrative closecut. -With additional l management. oversight a signif-
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icant number of these older: items were closed. ' Additionally, after the completion of the 11R-outage, additional emphasis;has been placed-
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In one approximately two month'
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- period-(June through July 1987), the total backlog of'short forms was-
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H reduced from..approximately 1176 to 890.
This.is a significant reduc-tion:and, although part of'the reduction came from straightening out-paperwork, it appears that the licensee has made progress in reducing
the actual number of work items to a more manageable size.
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_The inspe' tor'was also able to determine that only nineteen c
corrective maintenance i_tems were being held up for spare parts.
This concern that a lack of spare parts existed had been raised due to a number of instances where it appeared that certain equipment had-been scavenged to repair similar equipment.
It appears that this is.
not currently a.significant problem.
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The licensee is still in the process of implementing the GMS-II sys-
-tem for initiating, controlling, planning, and tracking individual
. work items. When fully implemented, a significant time savings should be realized in the processing and job planning for individual work items which should also help ensure that work items are correc-ted'on a more timely basis.
The licensee is targeting for a January 1988 full implementation of this system, but completion of the computer support services work could delayed this until July 1988.
y Although the maintenance backlog is still relatively large, the act-L ual number of items that af fect safety related equipment is low.
ls The majority of the corrective maintenance items are prioritized in order of importance and tracked in daily Plan of the Day (POD) meet-
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ings.
New items (short forms) are reviewed daily by a committee from the Operations, MCF, and Plant Materiel organizations to ensure that proper priority is established.
The inspectors observed ti.ese meet-ings on various occasions and evaluated the process as effective.
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The POD _ meetings, in particular, were very professionally and
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effectively conducted, and involved good exchange of information.
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i The P0D' meetings are considered a strength in promoting strong interfaces.
The licensee appears to be in control of the maintenance backlog problem and the inspectors concluded that the licensee has escalated-his efforts to complete long overdue' items.
5.6' Reliability Centered Maintenance Program The inspection team was uniquely interested in the licen::ee's program
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for addressing plant aging issues and the ongoing efforts to reduce the amount of maintenance rework.
The licensee's response in ad-
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dressing these concerns includes, in part, establishing a reliability centered ma'.ntenance program.. Under the MCF division, Plant Materiel will' develop and implement the reliability centered maintenance pro-
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gram.
While the licensee's efforts in establishing this program were in.the exploratory stages at-the time of this inspection,.the team was favorably impressed by the initial work in this area. The team felt that'a well-administered reliability program could impact favorably on efforts to address plant aging issues, minimize main-tenance rework, and reduce the maintenance backlog.
5.7 Post-Maintenance Testing The licensee's post-maintenance testing program had recently under-gone extensive revision.
In the past,, abbreviated surveillance tests or on occasion, separately prepared component level tests were developed.
Recent program improvements consisted of the development of a large number of generic component level tests. These procedures had beer. implemented prior to this inspection and were found to be routinely referenced in specifying post-maintenance test require-ments.
These generic procedures serve only as guidelines in develop-ing specific post-maintenance tests.
For a replaced or repaired component, the maintenance planner is required to consider any opera-tional or system restrictions that could preclude direct application of the generic p'rocedure. As a simple example, the generic post-maintenance test for repacking a valve requires cycling the valve and adjusting the packing.
However, if stroking the valve would inad-vertently actuate a safety system or device (such as a low flow alarm), the generic procedure would be revised accordingly.
The licensee views post-maintenance testing and operability testing as separate entities.
Consequently, the past practice of using an abbreviated surveillance procedure was no longer routinely used.
The inspection team found the licensee's effort in upgrading the post-maintenance test program to be a noteworthy.
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' 5.8J General Observations and Conclusions 1
- The produ'ction department of the' MCF division was found to be ade-h quately staffed.in all areas. LThe111censee's' strong commitment to-
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' craft training was evident by_the extensive training facility o'n'
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X site. --Some mechanical 2and:I&C. craftsmen expressed dissatisfaction'
with current. training. opportunities, however, the inspector.
determined thatlthis was due primarily to an, incomplete understanding-of the long-term training process. -The.MCF division training' program:
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-.does provide. advanced training for:all crafts:after the basic train-
' ng program has been administered.
Production: department' personnel-i s
appeared to have due regard for the importance;of safety-related
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equipment.
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The overall ALARA awareness in the: production department was high.
.The use of mock-ups in preparing for complex jobs in high radiation'.
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Lareas,: improved maintenance techniques (suchias laser alignment of
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pump shafts), and feedback from maintenance personnel =during inter-
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views form the basis of this observation.
However, theLteam was
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concerned about the' work ethic in the work shop.' Apparently, workers-are discouraged from returning to the work shop, even ifLa. job has.
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been completed, until the end of the work day. The team was. con-cerned'that this could adversely impact on the ALARA program
'(Observation). Additionally, the team.found that mechanical workers-did not appear to have the confidence of plant management and the licensed' operators (Observation).
Vendor manuals appeared to be adequately controlled.
Quality control inspectors. appeared-to be knowledgeable and effective in the. main-tenance. area.
The procedures reviewed during the course of this Linspection appeared to.be well written.- The MCF division was found to be posturing itself to properly address plant aging issues and taking positive. steps in reducing the maintenance backlog.
6.0 Plant Engineering 6.1 Scope and Review-l Plant Engineering (PE) programs were reviewed to assess their ability-to' enhance plant safety and meet regulatory requirements and Final Safety Analysis Report (FSAR) commitments.
In implementing the program review,.the team placed special emphasis on plant engineering task performance and functional responsibilities; Technical Functions interface; and control, prioritization, and evaluation of backlog.
6.2 Objectives The r:bjectives of the Integrated Performance Assessment Team in the area of PE was to gauge the performance of the department in the
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following areas:
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the ability of PE managers to develop, implement, and make clear
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at.all levels goals which will improve its performance and productivity;
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the ability to plan and control routine activities, such as l
plant procedure development changes, solving day-to-day PE problems, modification design work, training, safety reviews, and engineering calculations; understanding by workers / supervisors of impact of day-to-day
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actions on nuclear safety;
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effectiveness of training, direction and supervision by first-line supervisors;
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adequacy of staffing;
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role of QA in monitoring PE activities;
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controlling the backlog of PE-assigned tasks, including track-ing and validity of closecuts;
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quality of work and attention to detail; and,
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interface with other plant departments and Technical Functions.
In addition, the team conducted a limited evaluation of the perfor-mance of Technical Functions in support of PE.
6.3 Major Areas Reviewed 6.3.1 Plant Engineering Functional Responsibilities Until recently the PE Department's major responsibility has been the preparation and updating of all plant procedures.
The responsibility for maintenance and operations proced-ures has now been shifted to the Maintenance and Operations Departments, respectively, and PE is increasing its areas of responsibility to include modification design work and is taking a more active role in day-to-day PE activities.
The team reviewed the process and procedures used by PE in l
the conduct of modification work and routine work in sup-port of plant operations.
The team reviewed several safety-related calculations performed by PE, as well as task files for modification work performed by PE.
Addi-tionally, the governing procedures were reviewed to evalu-ate their adequacy and applicability for the work being performed.
Team members attended daily department meet-ings, POD meetings, and a Plant Engineering Design Review meeting.
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The temporary variation process wast reviewed.in order to'
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assess its impact:on. plant' configuration control.: The PE'
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. backlog list was reviewed and evaluated'concerning'estab-
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lishment of priorities,; reduction-of backlog, and. impact.on
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plantLsafety. The interface with.TechnicaliFunctions was,
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. evaluated, including responsiveness, qualitylof work, and
. support.in performing modifications.
Finally, the' te'am reviewed the PE backlog'. list and dis-cussed the' approach to reducing the backlog to a manageable number and the commitment of resources to accomplish..this m
"L task.
'The PE organization appears to have high morale and to.be1
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.well motivated and. capable of handling.the' additional responsibilitiesLit plans' to assume.
PE has prepared'several modification packages for non-safety-related equipment and intends to expand its scope to
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' include safety-related' work.
PE is presently.using.
Technical Functions Procedure EMP-19 -(Plant Modifications
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Engineering by PE) to perform this. work. A procedure aligned ~to the PE organization, which specifies in detail how modification work i.s to be performed, when done under PE cognizance, is needed'to enhance the quality and control of work.
It is the team's. understanding that a procedure-is.being' prepared and that PE will not. perform safety-related modifications until the new procedure is approved.
(This understanding was confirmed at the exit interview).
PE calculations reviewed, although technically adequate,
.were inconsistent and missing key elements.
PE calcula-tions did not clearly state purpose, identify references
and list assumptions. The team believes that the guidance contained in OCNGS Procedure 125 concerning engineering calculations is inadequate and a procedure for performing-engineer'ing calculations should be prepared.
Based on the above finding relative to' procedures for mini-mods and engineering calculations, the team concluded
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there is a lack of appreciation of the need for clear and effective administrative controls for Plant Engineering
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activities (Weakness).
OCNGS Procedure 125, Plant Modification Control," con-
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tained several references to the Plant Operations Review Committee (PORC), which indicates that the procedure has j
not been updated to reflect the new safety review organization that has been in effect for several year _ _ _ _ _ - -. _ _ _ _ _ _ _ _ _ _ _ _ _ _
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'During its review of the temporary variation program, the team found several temporary variations on safety related equipment which have been in place for two or more years.
These include differential pressure gauges on the
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containment spray heat exchangers, inoperable Standby Liquid Control System (SLCS) tank level gauges, and the addition of test manifolds to the Scram Discharge Instrument Volume (SDIV) drain valves.
In.the case of the added test manifolds, the monthly surveillance procedure has not been updated to reflect the actual plant configuration. The team believes that tighter control over temporary variations is needed and understands that'a major i
revision to this procedure has been prepared and will be implemented shortly (Observation).
The failure to update the SDIV surveillance procedure is considered an additional example of the previously cited weakness relative to appreciation of administration controls.
i PE is the " owner" of a very large number of plant
procedures, including many that are routinely used by other groups.
Some PE personnel seemed to be bogged down with routine maintenance of plant procedures (Observation).
PE has established the Backlog Working Group with committed resources. The charter of this group is to verify the validity of the list, establish priorities, assign and resolve backlog items, and track the list. As of this inspection, most of the reduction of the backlog list was due to removal of unnecessary items and duplicates; how-ever, the additional resources have begun to have an effect on resolution of legitimate items and should continue to reduce the backlog.
6.3.2 Instrument Setpoints The team reviewed several safety-related calculations (high power / flow scram and rod blocks, and high flow scram)
prepared by PE and OCNGS Procedure No. 125, " Conduct of Plant Engineering." Additionally, discussions with Tech-nical Functions personnel concerning design basis safety limits and conduct of safety-related instruinent setpoint calculations were conducted.
Safety-related instrument setpoint calculations are not addressed by either Technical Functions or PE procedures and do not reflect current state-of-the-art methodology (Weakness).
Technical Functions has prepared a draft procedure governing the preparation of instrument setpoints and limits. This procedure, when implemented, will invoke the latest Instrument Society of America guidance on l
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' safety-related~ instrument setpoint calculations and will Lmeet-the intent of Regulatory Guide.(RG) 1.105..This procedure'will; govern calculations performed by both Technical Function's and PE'and will.potentially strengthen
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.this weak area.
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In reviewin'g'thisLitem, the inspector determined that'FSAR-depiction.of'RG' commitments is very unclear. The inspector attempted to determine, using.the FSAR,'whether the: licensee'is committed.to'RG1.105.
FSAR tables on RG commitments list RG-1.105 and provide a number of cross-references, creating the impression, upon a cursory review, that there'are some commitments.to RG 1.105.
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However, a meticulous review of the cross-references will
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indicate that there is actually no commitment to RG 1.105..The same appears true for several'other RG's.
A clarification of the FSAR is needed (Observation).
. Technical Functions has' undertaken a program to establish a verifiable design basis for plant safety limits. >This pro-
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gram is based on the Statistical Combination of Uncertainty
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Analysis from the EPRI Reactor Analysis Support Package.
This program is both innovative and has the potential to develop into a strength.
6.3.3
. Quality Assurance The team held discussions with the Manager of Quality Assurance and the Manager of Operations Quality Assurance concerning the programmatic and-technical assessment of the day-to-day functions of PE.
The team also interviewed the
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Manager of the On-Site Review Group to determine what i
aspects of PE they review and assess.
Several Audits and Monitoring Reports were reviewed to determine the depth and breadth of these reviews.
The QA group is not intimately involved in the day-to-day activities conducted by PE; this includes both programm tic
and technical assessments. This is evidenced by QA not j
reviewing PE calculations; not identifying that the i
procedures governing the conduct of calculations are inadequate; not reviewing modifications conducted by PE; not reviewing of PE changes to surveillance procedures; and not reviewing Field Change Notices (FCN's) and Field Change Requests (FCR's) which are technical in nature (Weakness).
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The Independent On-Site Review Group (10SRG) and other such L~
groups provide needed technical reviews of some PE
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functions to help assure quality.
These reviews help fill I
the gap not covered by QA but should not be counted on to l-perform a function which is under the charter of QA.
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6.3.4 System Engineers and Systems Working Groups One program'that the plant engineering division is in the l
process of implementing is the concept of system engineers.
The engineering staff are assigned systems based on.their.
background and experience.
It is intended these engineers become the system experts on their assigned systems.
The function of these system engineers would include respon-sibility for the operation and surveillance procedures, responding to plant operational needs in the area of l
troubleshooting, maintaining the system's history, being a
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plant contact for interfacing with the Technical Functions group on modification packages,.and trending the systems performance.
The system engineering concept will support the System Working Group.
The System Working Group is a concept on the drawing board that will provide the means to assign system reliability goals and performance standards for each
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plant system.
Each system will be assigned to a working group consisting of a member from plant engineering (the system engineer), maintenance, operations, and technical functions (corporate engineering).
This group will be responsible for planning needed maintenance, maintaining system status, and trending performance to meet determined reliability goals set by the group for the system.
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reliability goals will be based on required system perform-ance needed to support the plant in achieving its capacity
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factor goal.
These concepts can develop into solid programs; however, there is no formal management procedure outlining these programs.
The Plant Engineering Division has begun the implementation of the system engineer program by making the individual assignments.
However, job responsibilities and minimum training requirements are not specified.
In order for the program to be effective, the team believes a formal commitment to the project needs to be made by means of a PE procedure or policy statement that should include as a minimum the statement of responsibilities, formal training and experience requirements, guidelines for resolving potential interface problems, and a policy commitment outlining the PE Division's planned implementation schedule (Observation).
6.3.5 Safety Review Process Incidentally to inspector review of PE functions, the safety review process was examined.
This was accomplished by reviewing the GPUN procedure, review of selected safety evaluations, discussions with the safety review manager,
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and various qualified responsible technical reviewers (RTR's) and independent safety reviewers (ISR's).
GPUN has abandoned the review of safety evaluations by a committee of senior level managers from various disciplines within the plant organization, known as the Plant Operations Review Committee.
The licensee has implemented a procedure l
that involves separate reviews by qualified RTR's and ISR's.
Two observations were noted.
During the reviews of various Safety Evaluations, it was noted that there was little consistency in the method the paperwork was prepared and that there remains some confusion as to which signature block is to be used in accordance wi.th the divisions procedure. This is indicative of inadequate training.
In the area of training given to the RTR and ISR, it was fcund to consist of only a four-hour oral presentation with no method to gauge the effectiveness of the training.
It was also noted that there exists no formal training given to the personnel who prepare and present the Safety Evaluations (Observation).
It should be stated that the majority of personnel who prepare the Safety Evaluations are RTR qualified, but there still exists a few preparers who do not meet the qualifications of an RTR, The second observation is that even though the division's Safety Evaluation procedure includes the provisions to use the Plant Review Group (PRG) in the capacity similar to the PORC, it was found that Oyster Creek does not take advan-tage of this resource.
The team believes that the review by a management level committee can provide a more consistent, integrated review of complex safety issues (Observation).
6.3.6 Seismic Mounting of Hydraulic Control Units (HCU's)
During a plant tour on August 11, the team noted that (1)
not all the HCU's were mounted in a back-to-back con-figuration, and (2) for those HCU's mounted back-to-back, the back-to-back frame bolting was inconsistent, in that there were many examples of missing bolts, missing washers and loose nuts.
Based on one of the inspector's knowledge that the vendor's original seismic qualification was only for back-to-back mounting, the team questioned the seismic qualification of the existing configuration.
By August 21, the licensee's Technical Function division was able to produce information that the HCU's had been analyzed as free-standing during the SEP program and during evaluation of HCU mounting discrepancies identified in 1986 (reference NRC inspection 86-33).
Also the licensee
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performed a more ' sophisticated confirmatory analysis s
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lduring this in'spection.and' presented the' preliminary;
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results to the inspector on. August 21.
-With respect to'this item, the inspector noted that:the
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which entailed extensive licensee' effort. The inspector-had to.be: inferred from a detailed review of the' analyses, l'
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pointed out that, as the plant ages,. questions regarding
.theras-built configuration will. continue to be raised..
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Better documentation and traceability.of the. dispositions can lead to more. efficient resolution of such questions inf the; future.
TheLinspector.further pointed out that this philosophy also~has. applicability to situations invo.lving
. electrical cables decommissioned'in place,' pipe supports an'd: anchors ' disqualified during IE. Bulletin 79-02: reviews, and equipment or; structural deficiencies evaluated
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use-as-is".
Traceable dispositions, including tagging or labelling'of affected equipment where appropriate, can promote more efficient'use of resources (including
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' licensee management, QA/QC personnel, NRC inspectors, and'
licensee engineering resources) involved in safety-verification' (Observation).
6.4. Conclusions There are some developments under way in.PE which may develop into strengths, but none which would be characterized as such based on:the current implementation status.
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.Although PE has made a considerable resource commitment to the reduc---
tion of backlog items,.the reduction in numbers to this point is.
mainly due to elimination of unnecessary and duplicate items.
Therefore, a true assessment of backlog reduction cannot be made at this time.
-The area of temporary variations continues to be an area of concern.
The strengthening of the procedure governing this area should be accomplished promptly and continued close attention by both the licensee and the NRC should continue.
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The system engineering concept has potential to become a positive strength, however, it needs a management commitment to define respon-sibilities, gesis and interfaces, training and implementation.
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The Safety Review process should make better use of the Plant Review Group in assessing the safety significance of major modifications or t'
complex issues involving interfaces with more than one department.
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- 7.0 Summary; J
LThe preceding-five sections discussed. details -ofL team'.s findings and
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L Lincluded a conclusion; paragraph in the areas included"within' the scope.of
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the' inspection.
In summarizing and evaluating these findings, the team
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looked.for common threads that: indicated generic. strengths, fundamental;.
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.weakn' esses,-and.other= observations common to more than one division.of;the
There did not appear to be'any pervasive fundamental weaknesses. This may. result f rom the. matrix form -of-organization applied at Oyster.
Creek whereinjno single individual below the corporate president has total
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responsibility.for_all'the site activities.
The GPUN matrix organization
.has historically had ' interface problems but it was. felt by the team that
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. inter-division interfaces and team work were improving.
In evaluating observations relative to interfaces,'the team identified
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the'following areas that should be evaluated by the licensee'for J
improvement (Observation).
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(1): L The Tech Functions - Radcon interfaces needs improvement:of the ALARA
' estimates-for long-term job planning, and more timely provision of I
outage job information from Tech Function for on-site Radiological Engineering review.
(ii) Regarding the Operations /MCF/ Plant. Engineering interfaces, Plant Engineering should, in many cases, be consulted earlier in review of plant problems..Also, system engineers should be more involved in surveillance test results review and in the performance of major e
tests.
(iii) Health Physics technician work hours do not conform to those of I
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other site workers, creating problems in continuity of work and HP l
coverage.
The team also made a number of observations that were common to more than one division but were neither sufficiently widespread nor sufficiently I
outstanding to be considered as generic strengths or weaknesses.
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(1) The team noted a clarity of responsibility and authority in the Operations and MCF Divisions, each under a strong line organization.
On the other hand, Radiation Control appeared less clear regarding responsibilities within the Division.
(2) The team also concluded the overall organization is under extensive transition in terms of program definition.
These changes are appropriate with the exception of the dilution of expertise in the respiratory protection and calibration programs.
(3) The inspectors observed remnants of informality and lack of attention to detail.
Examples include minor deficiencies in plant hardware, inconsistency in housekeeping practices, performance of a surveillance using an out-dated procedure, and informality of Plant i
Engineering calculations and use of the mini-mod process.
The team also saw remnants of a philosophy that procedures are too hard to t
change and a feeling that it is not essential to have a procedure that is precisely correct. Management in general, however, appeared to have a good attitude in these areas and a substantial portion of the first line supervisors did also.
The team believes that if management insists on a more universal understanding of their philosophy in these areas and offers consistent support, that the l
remaining problems can be eliminated (Observation).
Comparison of the findings with the inspection objectives indicated to the team that management objectives are clearly stated, understood at upper levels of management, and tracked to determine whether or not they are being accomplished.
It was noted, however, that these goals were not as well understood at lower levels of the organization and that promulgation of the goals to the lower levels could better aid in their accomplishment (Observation).
Planning and controlling routine activities was adequate.
The understanding by all personnel of the importance of nuclear safety was found to be generally acceptable; however, improvement is needed in the areas of risk perspective and understanding the design basis of the plant (Observation).
Specifically, the team felt there was insufficient understanding of (1) why the standby and passive safety systems are important; (2) why the second set of secondary containment doors is important; and (3) what accident sequences dominate risk, and therefore, what equipment is most important. Additionally, the team expected someone in the organization would have ownership of the hydraulic control units (HCUs) and would be making sure the HCUs were inspected regularly and maintained.
Furthermore, based on past HCU seismic deficiencies, it was expected that everything related to the as-built seismic condition would, by now, have been thoroughly investigated.
The effectiveness of training, direction, guidance and supervision by first line supervisors in all divisions was found to be generally ade-quate, although effectiveness could be improved by reducing the first line supervisors' administrative work load.
The effectiveness of the safety
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review process-is still in' question based on the vacuum breaker event but
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the" team felt the system wcs workable..The team also concluded the
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process could.be, improved.by.more. frequent.use of the. Plant Review Group I
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for unique and/or complicated issues and procedures.
Staffing in all
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. areas 11nspected seemed adequate and' involvement by senior: management in
' day-to-day operation.of.the plantJwas good.
There was evidence of QA/QC
involvement in the areas inspected.
QA/QC activities were noted to be i
- supplemented by several effective independent oversight groups.
In' conclusion,. the NRC has, in.the. past, experienced fru_stration with how long it. takes for planned improvements to come to fruition:at Oyster
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. Creek. While.the team.saw a positive trend in'this respect, it also.
L experienced some'of the frustration with slow improvement.
Because Oyster Creek has-been such a reactive: plant, there are often times, incomplete
solutions to problems. This situation appears to be improving; however, a conscious. awareness on the part of all involved is necessary to overcome
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..the tendency to lose pursuit of.a problem resolution if an obvious solution is notlavailable.
The team believes the recent emphasis on teamwork ~will help improve performance-in-many areas and will also play a key part in the success of.the many improvement programs. As to the-
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improveme'nt program efforts, there needs to be a sound consideration of not only the:long term goals, but careful consideration of what efforts
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Examples that give rise to this concern include the recent problem with the safety review process and temporary variations, the' weak interim setpoint methodology. program, and the inadequate storage of gas bottles in the plant.' It would seem to be prudent to have continuing feedback from reviews of the long term programs to determine what additional real time
- improvements need to be applied until each new program is fully and successfully implemented (Observation).
L 8.- 0 Followup-of Findings.
D; Based on the nature of the inspection findings, the team concluded that it was most appropriate to group the findings into strengths, weaknesses and observations. Throughout this report, those weaknesses and observations which the team considered significant enough for NRC followup are noted parenthetically. At the exit meeting, the licensee was requested.to keep the resident inspectors verbally informed of licensee evaluations and response actions for the findings. Also, the licensee was advised that on-site followup review, probably involving the resident
. inspectors and supervision from NRC Region I, would be scheduled in several months for the licensee to update NRC on all items.
Finally, the licensee was advised at the exit meeting that NRC Region I may, at its l
discretion, request written responses to selected findings.
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NRC Region I followup of the findings will be tracked as an open item (50-219/87-24-01).
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- 9.'0 Exit Int'erview-
- A: summary of.the results:of-the team's inspect' ion activities was performed
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on!a daily basis throughout the. inspection period with senior: plant.
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. management and:at-the end.oftthe period with.seni.or corporate and plant; management. During the final-exit interview, a concern.'for ALARA.and per-formanceLof necessary work: activities wasiraised-by the NRC.
In particu-41ar,' the NRC. stated they wanted to clarify to.GPUN:that!the NRC's concern
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for the' annual; radiation' exposure. values should not be misconstrued as a
. statement to.not perform necessary work in-order'to_ avoid: exposure.
The,.
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Executive Vice Pres.ident'for GPUN responded'to this tissue and stated.GPUN
- l-fully understo'd the NRC's position and had no intention:of' eliminating
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!necessary work- (i'.e., necessary from.a nuclear safety. standpoint) ~from
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-short or long: term plansto' reduce radiation: exposure.
The Nc'ensee stated that, :of'thel subjects, discussed at-the exit inter-
' view,'no proprietary information was included.
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Y ATTACHMENT 1-
. Persons Contacted
K.; Bass,-MCFIDivision Sta'ff< Supervisor
LR.JBrown,: Plant Operations:-Manageri j
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.T. Brownridge,LOutage. Manager
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J. Camire, LStation-Supervisor,1 Technical Functions.
.P. Ceruenka,~' Supervisor, Operations Engineering Jn Chardos, Long Range' Planning
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..R.LCroll,. Radiological; Engineer,; Technical Functions P. Crosby, Manager,JBacklog. Work Group
"J. DeBlasio',. Manager,' Mechanical; Engineering q
T. Dempsey,fReactor Plant Manager.
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,B. Falzarano,' Supervisor, Operator: Maintenance.
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P. Fiedler, Vice President.and Director, Oyster Creek Division R. Fenti, Manager,fQuality Assurance K. Fickeissen, Manager, On-Site-Safety Review' Group
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- V. Foglia, Manager, Preventive' Maintenance t
p S. Fuller, Manager,' Operations QA
- T. Gafferey,
- Electrical /I&C Material Manager R. Harkleroad, Supervisor, I&C! Engineering
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J.- Hascak,. Plant Material i
T. Jenkins,; Supervisor, MCF
? - *E.'.Kintner, Executive Vice President-, GPUN
~ J. Kowalski, Licensing Manager
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LR. Larzo, Supervisor,= Spare Parts Engineering
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,M. ?Littleton, Manager, Radiological Engineering R.lLong,-Vice President, Planning and Nuclear Safety
'D. McFarlane, -QA Audits Supervisor K.' Mulligan, Staff Engineer
.1 M. Radvansky, Manager, Site Technical Functions
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De Ranft, Manager, Electrical. Engineering
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N. Roche, Vice President and Director, Quality and Radiological Controls-J. Rogers, Licensing Engineer
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A. Rone, Plant Engineering Director
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' D. Slear, Fluid Systems Director M. Slobodien, Director, Radiological Controls W. -Stewart, Safety Review Manager J. Sullivan, Director, Plant Operations M. Szmidt, Human Resource Manager N. Trikourous,. Manager, Safety Analysis and Plant Cond.
.J..' Williams, GET Training Supervisor R. Beck, Radcon Training Supervisor i
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' P. Conaly,. Dosimetry Supervisor P. Ritchie, Radcon I&C Supervisor F. - Applegate, Respiratory Protection Maintenance Sepervisor
- Senior licensee manager present at exit meeting.
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ATTACHMENT 2 r,
j Principal Document's Reviewed.
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Station Procedures l
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Procedure No. 116,l Revision 21; " Surveillance Test Program"
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Procedure.No. 112.1;.-Revision 24, " Technical Specification Supporti.ng
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' Installed Instrumentation" i
L Procedure.; No. 112, Revision 17,."0yster Creek Calibration!of_ Maintenance
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Test: and'. Inspection Tools, Gauges and Instrumentation"
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Procedure'610.3.105, '.' Core Spray System / Instrument Channel Calibration and j
' Test" i
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-- '. P rocedike' 610.4.~002, " Core Spray Pump' Operability Test"
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. Procedure 651.4.001,." Standby Gas TreatmentiSystem"-
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' Procedure 115, " Standing Order-Control"
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Procedure 106, Conduct of Operations"
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Procedure 104, " Control of Nonconformances and Corrective Actions"
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Procedure!105, " Conduct of Maintenance"
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' ' Procedure105.3, " Maintenance of Oyster Creek Environmental Qualified
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Equipment" Procedu're ' 108.4, " Control of Plant Modifications and Major Maintenance
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Work in Critical Plant Areas While the Plant is in Operation"
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'I Proce'ure 114, " Testing" l
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Procedure 118, " Preventive Maintenance Administration Procedure" J
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~ Procedure 118.1, " Plant Equipment Failure and Performance Data Trend
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P'rocedure 119, " Housekeeping"
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Procedure 101, " Organization and Responsibility"
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Procedure 107.iL,"DrawingControlProcedure"
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Procedure ~107.2, " Drawing Status Violation Procedure"
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' Attachment 2
Procedure 130, " Conduct of Independent Safety Reviews and Responsible
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Technical Reviews of Plant Review Group" Procedure 125, " Conduct of Plant Engineering"
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Procedure 124, " Plant Modification Control"
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Procedure 108, " Equipment Control"
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Procedure 619.3.011, " Scram Discharge High Water Level Test"
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Procedure 620.3.003, "APRM Surveillance Test and Calibration Procedure" MCF Division Procedure A000-ADM-7175.01, " Post Maintenance Testing"
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Procedure A000-WMS-1220.01, " Work Request"
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Procedure A000-WMS-1220.03, " Work Authorization"
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Procedure 5000-ADM-7311.03, " Technical Functions Division"
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Procedure 5000-ADM-5110.01, " Project Approval and Work Authorization" Procedure 5000-ADM-6250.01, " Professional Services"
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Procedure 9300-ADM-4010.02, "ALARA Review Procedure" Procedure 1000-PLN-4010.01, "GPU Nuclear Corporation Radiation Protection
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Plan" Procedure 1000-POL-4010.01, " Radiation Protection Policy"
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Technical Functions
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Procedure ES-002, " Instrument Setpoints and Limits" Draft
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Procedure ES-007, "ALARA Guidelines for Configuration Changes" Quality Assurance
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Audit Report S-0C-86-02, Subject:
Modifications Audit Report S-0C-86-08, Subject:
Plant Engineering
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QA Monitoring Report 6122-1-8622079
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QA Monitoring Report 6122-1-8622090
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QA Monitoring Report 6122-1-8622102
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Attachment 2 3-
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--.QA Monit'oring Report 6122-1-8710104 QA Monitoring. Report 6123-1-8622095
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.QA Monitoring Report 6122-1-8610104
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